NOC-AE-08002345, Units 1 & 2 - Supplement 1 to License Amendment Request for Deviation from Fire Protection Program Requirements

Units 1 & 2 - Supplement 1 to License Amendment Request for Deviation from Fire Protection Program Requirements

ML082590007
Person / Time
Site:	South Texas
Issue date:	09/05/2008
From:	Harrison A Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-08002345, STI: 32355702, TAC MD6694, TAC MD6695
Download: ML082590007 (7)

Text

Nuclear Operating Company South Texas PmrectElectric GeneratinS Station PO B&x 289 Wadsworth, Texas 77483 September 5, 2008 NOC-AE-08002345 10CFR50.90 IOCFR50.48 STI: 32355702 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MID 20852-2738 South Texas Project Units.1 & 2 Docket Nos. STN 50-498, STN 50-499 Supplement 1 to License Amendment Request for Deviation from Fire Protection Program Requirements (TAC Nos. MD 6694 & MD 6695)

Reference:

Letter from STP Nuclear Operating Company to the NRC Document Control Desk, "License Amendment Request for Deviation from Fire Protection Program Requirements," dated August 27, 2007 (NOC-AE-07002169)

In the referenced letter, STP Nuclear Operating Company (STPNOC) requested a license amendment for a deviation from STPNOC Fire Protection Program Requirements. STPNOC requested that Attachment 2 of the referenced letter be withheld from public disclosure in accordance with 10 CFR 2.390. This supplemental letter provides the proposed change to the Operating Licenses, associated with the application, as Attachments I and 2 to this letter. In addition, this letter provides the reason for withholding Attachment 2 of the referenced letter from public disclosure.

The Nuclear Regulatory Commission (NRC) has currently approved the STPNOC fire protection program, in part, as described in the Fire Hazards Analysis Report through Amendment No. 7 as described in Operating License Condition 2.E., "Fire Protection." STPNOC requests that the deviation from fire protection program requirements requested by the referenced letter be approved as Amendment 18 to the Fire Hazards Analysis Report.

Changes to the STPNOC fire protection program, Amendments 8 through 17 to the Fire Hazards.

Analysis Report, have previously been approved by STPNOC. These changes are allowed to be

NOC-AE-08002345 Page 2 approved by STPNOC in accordance with Operating License Condition 2.E. because the changes did not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

These changes were reported to the NRC pursuant to 10 CFR 50.71(e). See Attachment 3 for a list of Amendments 8 through 17 to the Fire Hazards Analysis Report and the associated referenced letters.

The proposed change given in Attachments 1 and 2 agrees with the proposed change in the application provided in the referenced letter and does not change the no significant hazards consideration given in the application, for the proposed deviation to the fire protection program.

STPNOC requested that Attachment 2 of the referenced letter be withheld from public disclosure in accordance with 10 CFR 2.390. The basis for withholding is that the information discusses-mitigation strategies for achieving safe shutdown of the South Texas Project Units. This basis is similar to the basis for withholding information regarding Engineered Safety Features as discussed in NRC Commission paper SECY-04-0191, "Withholding Sensitive Unclassified Information Concerning Nuclear Power Reactors From Public Disclosure," dated October 19, 2004.

There are no commitments in this letter.

If there are any questions regarding this amendment request, please contact Ken Taplett at (361) 972-8416 or me at (361)972-7298.

ýIi~Harri*so~n Manager, Licensing kjt Attachments: I Proposed Change to South Texas Project, Unit 1, Operating License No.

NPF-76 2 Proposed Change to South Texas Project, Unit 2, Operating License No.

NPF-80 3 List of the referenced letters for Amendments 8 through 17 to the STPNOC Fire Hazards Analysis Report

NOC-AE-08002345 Page 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani Kevin Howell Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 7 D1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN116 Kevin Pollo Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department 721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189

Attachment I NOC-AE-08002345 Attachment 1 Proposed Change to South Texas Project, Unit 1, Operating License No. NPF-76 (One Page)

SOUTH TEXAS LICENSE (4) The facility has been granted a schedular exemption from Section 50.71 (e)(3)(i) of 10 CFR 50 to extend the date for submittal of the updated Final Safety Analysis Report to no later than one year after the date of issuance of a low power license for the South Texas Project, Unit 2. This exemption is effective untilAugust 1990. The staff's environmental assessment was published on December 16, 1987 (52 FR 47805).

E. Fire Protection STPNOC shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report through Amendment No. 55 and the Fire Hazards Analysis Report through Amendment No. L78, and submittals dated April 29, May 7, 8 and 29, June 11, 25 and 26, 1987, and as approved in the SER (NUREG-0781) dated April 1986 and its Supplements, subject to the following provision:

STPNOC may make changes to the approved fire protection program without prior approval of the Commission, only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

F. Physical Security STPNOC shall fully implement and maintain in effect all provisions of the physical security, training and qualification, and safeguards contingency plans previously approved by the Commission and all amendments and revisions to such plans.

made pursuant to the authority under 10 CFR 50.90 and 10 CFR 50.54(p).

The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822), and the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "South Texas Project Electric Generating Station Security, Training and Qualification, and Safeguards Contingency Plan, Revision 2" submitted by letters dated May 17 and 18, 2006.

G. Not Used H. Financial Protection The Owners shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

Amendment No.

Attachment 3 NOC-AE-08002345 Attachment 3 List of the referenced letters for Amendments 8 through 17 to the STPNOC Fire Hazards Analysis Report

Attachment 3 NOC-AE-08002345, List of the referenced letters for Amendments 8 through 17 to the STPNOC Fire Hazards Analysis Report Amendment No. Date of Letter from STPNOC STPNOC to the NRC Correspondence Number 8 October 31, 1991 ST-HL-AE-003919 9 January 25, 1993 ST-HL-AE-004297 10 January 31, 1995 ST-HL-AE-004960 11 March 10, 1997 ST-HL-AE-005553 12 July 28, 1999 NOC-AE-000470 13 July 23, 2001 NOC-AE-01001141 14 April 22, 2002 NOC-AE-02001307 15 April 13, 2004 NOC-AE-04001700 16 March 20, 2006 NOC-AE-06001993 17 March 6, 2008 NOC-AE-08002260