ML110280322

Issuance of Amendment Nos. 194 and 182, Revise Updated Final Safety Analysis Report Related to Reactor Coolant System Pressure Transmitter Replacement

ML110280322
Person / Time
Site:	South Texas
Issue date:	03/22/2011
From:	Thadani M Plant Licensing Branch IV
To:	Halpin E South Texas
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC ME3967, TAC ME3968
Download: ML110280322 (16)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 22, 2011 Mr. Edward D. Halpin President and Chief Executive Officerl Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS RE: APPROVAL OF REDUCTION IN DIVERSITY REQUIREMENTS FOR ISOLATION OF LOVV PRESSURE FROM HIGH-PRESSURE RESIDUAL HEAT REMOVAL SYSTEM (TAC NOS. ME3967 AND ME3968)

Dear Mr. Halpin.

The Commission has issued the enclosed Amendment No 194 to Facility Operating License No NPF-76 and Amendment No 182 to Facility Operating License No. NPF-80 for the South Texas Project (STP), Units 1 and 2, respectively. The amendments consist of changes io the Facility Operating Licenses in response to your application dated May 18, 2010, as supplemented by letter dated October 5, 2010 The amendments eliminate the Residual Heat Removal (RHR) system design criterion fOI" diversity among the three Reactor Coolant System pressure transmitters that generate interlocks for three series-pairs of RHR suction isolation valves. The change allows slmiiarly qualified pressure transmitters to be used In more than one RHR train as necessary regardless of manufacturer of the transmitters. The revision is incorporated in the Updated Final Safety Analysis Report for STP, Units 1 and 2.

E. Halpin -2 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,

-\.~

Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosures:

1. Amendment No. 194 to NPF-76

2. Amendment No. 182 to NPF-80

3. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 194 License No. NPF-76

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

A. The application for amendment by STP Nuclear Operating Company (STPNOC)*

acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), and the City of Austin, Texas (COA) (the licensees), dated May 18, 2010, as supplemented by letter dated October 5, 2010, 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 0) 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.

• STPNOC is authorized to act for NRG South Texas LP, the City Public Service Board of San Antonio, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Enclosure 1

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2. Accordingly, the license is amended by changes to the Updated Final Safety Analysis Report, 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. 194, and the Environmental Protection Plan contained in Appendix B. are hereby incorporated in the license. STPNOC 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 within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael 1. Markley, 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: March 22, 2011

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT. UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 182 License No. NPF-80

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

A. The application for amendment by STP Nuclear Operating Company (STPNOC)*

acting on behalf of itself and for NRG South Texas LP, the City Public Service Board of San Antonio (CPS), and the City of Austin, Texas (COA) (the licensees), dated May 18, 2010, as supplemented by letter dated October 5, 2010, 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.

• STPNOC is authorized to act for NRG South Texas LP, the City Public Service Board of San Antonio, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

Enclosure 2

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2. Accordingly, the license is amended by changes to the Updated Final Safety Analysis Report, and Paragraph 2.C.(2) of Facility Operating License No. NPF-80 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 182, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC 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 within 60 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Facility Operating License No. NPF-80 and the Technical Specifications Date of Issuance: March 22, 2011

ATTACHMENT TO LICENSE AMENDMENT NOS. 194 AND 182 AND FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 DOCKET NOS. 50-498 AND 50-499 Replace the following pages of the Facility Operating Licenses, Nos. NPF-76 and NPF-80 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Operating License No. NPF-76 REMOVE INSERT

-4 Facility Operating License No. NPF-80 REMOVE INSERT

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SOUTH TEXAS LICENSE -4 (2) Technical Specifications The Technical Specifications contained in Appendix A. as revised through Amendment No. 194. and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14, SER)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) Safety Parameter Display System (Section 18, SSER No. 4)*

Before startup after the first refueling outage, HL&P[**] shall perform the necessary activities. provide acceptable responses. and implement all proposed corrective actions related to issues as described in Section 18.2 of SER Supplement 4.

(6) Supplementary Containment Purge Isolation (Section 11.5, SSER NO.4)

HL&P shall provide. prior to startup from the first refueling outage. control room indication of the normal and supplemental containment purge sample line isolation valve position.

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

• • The original licensee authorized to possess. use and operate the facility was HL&P.

Consequently, historical references to certain obligations of HL&P remain in the license conditions.

Amendment No. 194

-4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 182 and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. STPNOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Not Used (4) Initial Startup Test Program (Section 14. SR)*

Any changes to the Initial Test Program described in Section 14 of the Final Safety Analysis Report made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.

(5) License Transfer Texas Genco, LP shall provide decommissioning funding assurance, to be held in decommissioning trusts for South Texas Project, Unit 2 (Unit 2) upon the direct transfer of the Unit 2 license to Texas Genco, LP, in an amount equal to or greater than the balance in the Unit 2 decommissioning trust immediately prior to the transfer. In addition, Texas Genco, LP shall ensure that all contractual arrangements referred to in the application for approval of the transfer of the Unit 2 license to Texas Genco, LP to obtain necessary decommissioning funds for Unit 2 through a non-bypassable charge are executed and will be maintained until the decommissioning trusts are fully funded, or shall ensure that other mechanisms that provide equivalent assurance of decommissioning funding in accordance with the Commission's regulations are maintained.

(6) License Transfer The master decommissioning trust agreement for Unit 2, at the time the direct transfer of Unit 2 to Texas Genco, LP is effected and thereafter, is subject to the following:

• The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Amendment No. 182

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 194 AND 182 TO FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 STP NUCLEAR OPERATING COMPANY, ET AL.

SOUTH TEXAS PROJECT. UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1.0 INTRODUCTION

By letter dated May 18, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML101450115), as supplemented by letter dated October 5,2010 (ADAMS Accession No. ML102860139), STP Nuclear Operating Company (STPNOC, the licensee) submitted a license amendment request (LAR) for Residual Heat Removal (RHR) system changes to South Texas Project (STP), Units 1 and 2. The supplemental letter dated October 5,2010, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on September 21,2010 (75 FR 57528).

The amendments eliminate STP, Units 1 and 2, RHR system design feature for diversity among the three Reactor Coolant System (RCS) pressure transmitters (PT-405, PT-406, and PT-407) that generate interlocks for three series-pairs of RHR Suction Isolation Valves. This design feature was described in the STP, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR),

and is credited in NUREG-0781, "Safety Evaluation Report Related to the Operation of South Texas Project, Units 1, and 2," April 1986 (not publicly available). A series-pair of RHR Suction Isolation Valves (XRH0060 with XRH0061) provide isolation for each redundant train (A, B, and C) of the RHR system. The pressure transmitters (PTs) generate low-pressure permissive signals to only allow opening RHR Suction Isolation Valves under suffiCiently low RCS pressure conditions. These pressure-based Open Permissive Interlocks (OPls) prevent opening both series-pair valves under conditions that could overpressurize the RHR system.

2.0 REGULATORY EVALUATION

In evaluating the LAR, the NRC staff used the following regulatory requirements and guidance that it considered applicable for the evaluation of acceptability of the proposed change.

• NUREG-0800, "Standard Review Plan [SRP] for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition,"

Enclosure 3

-2 Section 7.6, "Interlock Systems Important to Safety" (ADAMS Accession No. ML070460348), including Branch Technical Position (BTP) 7-1, "Guidance on Isolation of Low-Pressure Systems from the High-Pressure Reactor Coolant System" (ADAMS Accession No. ML070460345). The evaluation criteria in BTP 7-1 corresponds to BTP ICSB-3 as identified in STP UFSAR Table 7.1-1 in reference to UFSAR paragraph 7.6.2.2.

• Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 34, "Residual heat removal," which corresponds to Criterion 34 of STP UFSAR Section 3.1.2.4.5.

Criterion 34 of Appendix A to 10 CFR Part 50 states that, A system to remove residual heat shall be provided. The system safety function shall be to transfer fission product decay heat and other residual heat from the reactor core at a rate such that specified acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded.

Suitable redundancy in components and features, and suitable interconnections, leak detection, and isolation capabilities shall be provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure.

• In reference to Criterion 34 of Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50 requires, Consideration of redundancy and diversity requirements for fluid systems important to safety. A "system" could consist of a number of subsystems each of which is separately capable of performing the specified system safety functions. The minimum acceptable redundancy and diversity of subsystems and components within a subsystem, and the required interconnection and independence of the subsystems have not yet been developed or defined.

3.0 TECHNICAL EVALUATION

The NRC staff's safety evaluation for the STP RHR system isolation valve interlocks is documented in NUREG-0781, "Safety Evaluation Report Related to the Operation of South Texas Project, Units 1 and 2," dated April 1986 (not publicly available). NUREG-0781 Section 7.6.2.1, "Residual Heat Removal System Isolation Valve Interlock," documents the current PT diversity requirements of record which states that, The two valves in each RHR train receive pressure Signals from different pressure transmitters which are supplied by different manufacturers... The

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[NRC] staff finds that the RHR system isolation valve interlock design conforms to the independence, separation, and diversity criteria. The design also satisfies BTP ICSB-3, "Isolation of Low Pressure Systems from the High Pressure Reactor Coolant System." Therefore, the design of the RHR system isolation valve interlock is acceptable.

The configuration of the instrumentation and controls to provide PT diversity for the RHR system isolation valve interlocks is documented in Chapter 7.0, "INSTRUMENTATION AND CONTROLS," Table 7.6-1, page 7.6-14, of STP, Units 1 and 2 "Updated Final Safety Analysis Report (UFSAR)," Revision 14, dated April 30,2008 (not publicly available). However, Chapter 7.0 of Revision 15, dated April 29, 2010 (not publicly available), deletes Table 7.6-1 and the prior references to Table 7.6-1 (see Revision 15's change notice, CN-2924).

Revision 14's Table 7.6-1 identifies multiple PT manufacturers (Tobar, Barton, and Rosemont),

and manufacturer part numbers corresponding to strain gauge, bourdon tube, and capacitive sensing of diaphragm displacement from Tobar, Barton, and Rosemont manufacturers, respectively. The correlation of manufacturer/part number to pressure-sensing technology was determined from the identified manufacturer/part numbers. Table 7.6-1 maps the three PTs to controlled protection sets and series-pairs of RHR Suction Isolation Valves in such a way that different combinations of independent, separate, and diverse PT pairings are mapped to the valve pairings in each independent and separate RHR train.

The licensee proposes to eliminate this PT diversity by permitting a single sensor manufacturer and pressure-sensing technology to be used for all RHR system-controlled protection sets and each series-pair of RHR Suction Isolation Valves. In other words, while different combinations of independent and separate PT pairings will still be mapped to the valve pairings in each independent and separate RHR train to preserve independence and separation criteria of the OPls, the diversity associated with the use of different PT manufacturers and different pressure sensing technologies will be eliminated.

The current STP, Units 1 and 2, design criterion, proposed to be revised, provides an interlock to each valve in a series-pair where each PT is independent, separate, and made by a different manufacturer that uses a different underlying pressure-sensing technology. The different underlying pressure-sensing technology provides diversity among the PTs. This STP, Units 1 and 2, pressure-based interlock configuration prevents inadvertent RHR system overpressurization due to any single PT failure and provides additional protection against potential common-cause and common-mode failures of the PTs. Because the licensee does not otherwise change the RHR system configuration or modify its interlock functionality, this technical evaluation is limited to an evaluation of the independence and diversity that remains when a common pressure-sensing technology and manufacturer is used for the RHR system OPls. The independence and diversity that remains are evaluated against the applicable criteria of BTP 7-1.

BTP 7-1 Position B.2, states that, For system interfaces where both valves are motor-operated, the valves should have independent and diverse interlocks to prevent both from opening unless the primary system pressure is below the subsystem design pressure. Also, the

-4 valve operators should receive a signal to close automatically whenever the primary system pressure exceeds the subsystem design pressure.

In the original design at STP, Units 1 and 2, a signal automatically closed a valve, whenever the primary system pressure exceeded the subsystem design pressure, as an Automatic Closure Interlock (ACI). The ACls were removed from STP Unit 1 by Amendment 41 to License No.

NPF-76, dated August 19,1982 (ADAMS Accession No. ML021290151), and similarly removed from STP Unit 2 by Amendment 18 to License No. NPF-80, dated September 18, 1991 (ADAMS Accession No. ML021330715). Therefore, no further evaluation of the automatic closure criteria, identified in the second sentence of BTP 7-1 Position B.2, is provided in this safety evaluation.

The remaining safety evaluation addresses the interlocks that prevent both series-pair valves in an RHR train from opening unless the primary system pressure is below the subsystem design pressure. STP, Units 1 and 2, refer to these pressure-based interlocks as OPls. The design and behavior of the RHR system pressure-based OPls have not changed since issuance of NUREG-0781. The proposed amendment does not affect the behavior of the OPls, but rather proposes to allow each independent and separate PT that is used in each OPI circuit to come from a single PT manufacturer and use a common pressure-sensing technology. These amendments would retain pressure-based RHR system isolation valve OPI circuits for each valve in a series-pair, which is independent and electrically separate from its companion while allowing the pressure-based OPI to use a common pressure transmitter without diversity.

All STP, Units 1 and 2, RHR Suction Isolation Valves are motor-operated gate valves that require the plant operator to take action specifically to actuate each isolation valve. For each series-pair of valves in an RHR train, STP, Units 1 and 2, provide an alternative interlock for the inboard RHR Suction Isolation Valves (XRH0061 A, B, and C) that is independent, separate, and diverse from its companion valve (XRH0060 A, B, and C, respectively). Power to each inboard RHR Suction Isolation Valve can be secured and locked out in accordance with plant operating procedures and manually initiated actions without adversely affecting the pressure based OPI or control room indications. By plant procedure, the power to the inboard RHR Suction Isolation Valve motor for each RHR train is locked out in Modes 1, 2, and 3 after the valve has been confirmed as being closed. The power lockout provides an interlock for inboard RHR Suction Isolation Valves (XRH0061) which is independent and diverse from all pressure based OPls, which are present on each XRH0060 and XRH0061 valve. Power must be restored manually to the valve's motor operator by removing the power lockout interlock before opening an inboard RHR Suction Isolation Valve is possible. As an additional measure, the valve motor operators are sized to limit their ability to open a valve against full differential pressure between the RCS and RHR system.

Using an open permissive setpoint, the pressure-based OPI will allow RHR Suction Isolation Valve motor operators to open a valve when the sensed RCS pressure is below approximately 332 pounds per square inch gauge (psig). A control room alarm actuates if any RHR Suction Isolation Valve is open with the RCS pressure above the open permissive setpoint and below the RHR design pressure minus the RHR pump head pressure. Alarms will alert operators to reduce RCS pressure and close RHR Suction Isolation Valves whenever the RCS pressure is greater than 475 psig with an RHR Suction Isolation Valve not fully closed.

- 5 The plant procedures for RHR operation require that the RCS temperature not exceed 350 degrees Fahrenheit and the RCS pressure not exceed 350 psig before operators open the RHR Suction Isolation Valves. When an RHR loop is aligned and operating. its pump discharge PT will alarm the control room if its discharge pressure exceeds 540 psig. During plant heatup.

the RCS pressure can approach 425 psig before actions are taken to close the RHR Suction Isolation Valves. After the RHR Suction Isolation Valves are closed. the power to the inboard RHR Suction Isolation Valve motor operator for each RHR train is locked out in Modes 1, 2. and 3 to prevent an inboard RHR Suction Isolation Valve from opening.

As described in the LAR, STP Units 1 and 2 use a combination of pressure-based OPI. power lockout interlock. and manual operating procedures and actions to independently. separately.

and diversely prevent both series-pair valves that isolate an RHR system train from opening unless the primary system pressure is below the subsystem design pressure. The pressure based OPls that are used for the RHR Suction Isolation Valves closest to the RCS (XRH0060 A.

B. and C) are diverse from the power lockout interlocks that are used for inboard RHR Suction Isolation Valves (XRH0061 A. B. and C). Therefore. the combination of pressure-based OPI and power lockout interlock continue to provide protection against potential common cause and common mode failures of the PTs. Based on the above *. the NRC staff concludes that STP.

Units 1 and 2. will continue to satisfy the applicable portion of BTP 7-1 Position B.2 following the elimination of PT diversity for the RHR system isolation valve OPls.

Based on the above. the NRC staff concludes that the proposed amendment to eliminate PT diversity for the RHR system isolation valve interlocks satisfies with the regulatory evaluation criteria of BTP 7-1 and GDC 34. and is. therefore, acceptable.

4.0 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.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change 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 amendments involve 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 previously issued a proposed finding that the amendments involve no significant hazards consideration. and there has been no public comment on such finding published in the Federal Register on September 21, 2010 (75 FR 57528). Accordingly. the amendments meet 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 amendments.

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6.0 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: B. Dittman Date: March 22, 2011

ML110280322 *SE memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA DIRS/EICB/BC OGC NLO

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