Text

Issuance of Amendment Nos. 195 and 183, Revise Action Requirement in Technical Specification 3.7.7, Control Room Makeup and Cleanup Filtration Systems
	ML110950146
Person / Time
Site:	South Texas
Issue date:	04/25/2011
From:	Balwant Singal; Plant Licensing Branch IV
To:	Halpin E; South Texas
	Singal, Balwant, 415-3016, NRR/DORL/LPL4
References
	TAC ME4198, TAC ME4199
	Download: ML110950146 (19)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 April 25, 2011 Mr. Edward D. Halpin President and Chief Executive Officer/

Chief Nuclear Officer STP Nuclear Operating Company South Texas Project P.O. Box 289 VVadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PRO.JECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS TO REVISE THE ACTION REQUIREMENT FOR AN INOPERABLE CONTROL ROOM ENVELOPE BOUNDARY IN TECHNICAL SPECIFICATION 3.7.7, "CONTROL ROOM MAKEUP AND CLEANUP FILTRATION SYSTEM" (TAC NOS. ME4198 AND ME4199)

Dear Mr. Halpin:

The Commission has issued the enclosed Amendment No. 195 to Facility Operating License No. NPF-76 and Amendment No. 183 to Facility Operating License No. NPF-80 for the South Texas Project, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 28,2010.

The amendments revise TS 3.7.7, "Control Room Makeup and Cleanup Filtration System," to add shutdown actions if the required actions for an inoperable control room envelope (CRE) boundary are not met. The amendments also add a note to the required action for an inoperable CRE boundary to clarify that the boundary is not a required system, subsystem, train, component, or device that depends on a diesel generator as a source of emergency power.

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, b . . .\u........t \:-2>\~~

Balwant K. Sing ai, 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. 195 to NPF-76

2. Amendment No. 183 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. 195 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 June 28,2010, 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 ofthis 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

- 2

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. 195, 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 it 11 1 f ()O t?

~;ff--tJ- r'. '~ ~'t, II

~'

Mi el 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-76 and the Technical Specifications Date of Issuance: Apr; 1 25, 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. 183 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 June 28,2010, 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

- 2

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-80 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 183, 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 rA7~)J f' Micnael 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: Apri 1 25, 2011

ATTACHMENT TO LICENSE AMENDMENT NOS. 195 AND 183 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, and Appendix A Technical Specifications 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 4 Facility Operating License No. NPF-80 REMOVE INSERT 4 4 Technical Specifications REMOVE INSERT 3/47-16 3/47-16 3/47-17 3/47-17 3/47-18 3/47-18

SOUTH TEXAS LICENSE -4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 195, 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. 195

-4 (2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 183 and the Environmental Protection Plan contained in Appendix 8, 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. 183

PLANT SYSTEMS 3/4.7.7 CONTROL ROOM MAKEUP AND CLEANUP FILTRATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.7 Three independent Control Room Makeup and Cleanup Filtration Systems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4:

ACTION:

a. With one Control Room Makeup and Cleanup Filtration System inoperable for reasons other than condition d, within 7 days restore the inoperable system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With two Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least two systems to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With three Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

The Control Room Envelope (CRE) boundary is not a required system, subsystem, train, component, or device that depends on a diesel generator as a source of emergency power. Specification 3.8.1.1.d need not be applied for an inoperable Control Room Makeup and Cleanup Filtration System that is inoperable solely due to an inoperable Control Room Envelope boundary.

d. One or more Control Room Makeup and Cleanup Filtration Systems inoperable due to inoperable Control Room Envelope (CRE) boundary perform the following:

1) immediately initiate action to implement mitigating actions, and

2) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months verify mitigating actions ensure CRE occupant exposures to radiological, chemical and smoke hazards will not exceed limits, and

3) within 90 days restore CRE boundary to OPERABLE status.

OR be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SOUTH TEXAS - UNITS 1 & 2 3/4 7-16 Unit 1 -Amendment No. 5Q, 125, 128, ~488, 195 Unit 2 - Amendment No. 47, 11 a, 117, 4e&; 4+&,-183

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS 4.7.7 Each Control Room Makeup and Cleanup Filtration System shall be demonstrated OPERABLE:

a. At a frequency in accordance with the Surveillance Frequency Control Program by verifying that the control room air temperature is less than or equal to 78°F;

b. At a frequency in accordance with the Surveillance Frequency Control Program by initiating, from the control room, flow through the HEPA filters and charcoal adsorbers of the makeup and cleanup air filter units and verifying that the system operates for at least 10 continuous hours with the makeup filter unit heaters operating;

c. At a frequency in accordance with the Surveillance Frequency Control Program or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire, or chemical release in any ventilation zone communicating with the system by:

1) Verifying that the makeup and cleanup systems satisfy the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% for HEPA filter banks and 0.10% for charcoal adsorber banks and uses the test procedure guidance in Regulatory Positions C.5.a, C.5.c, and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and the system flow rate is 6000 cfm +/- 10% for the cleanup units and 1000 clm +/- 10% for the makeup units;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989, "Standard Test Method for Nuclear-Grade Activated Carbon," for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30°C and a relative humidity of 70%; and

3) Verifying a system flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/-

10% for the makeup units during system operation when tested in accordance with ANSI N510-1980.

d. After every 720 hours0.00833 days 0.2 hours 0.00119 weeks 2.7396e-4 months of charcoal adsorber operation, by verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of ASTM D3803-1989 for a methyl iodide penetration of less than 1.0% when tested at a temperature of 30°C and a relative humidity of 70%.

e. At a frequency in accordance with the Surveillance Frequency Control Program by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6.1 inches Water Gauge for the makeup units and 6.0 inches Water Gauge for the cleanup units while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm +/- 10% for the makeup units; SOUTH TEXAS - UNITS 1 & 2 3/47-17 Unit 1 - Amendment No. +2+, 4-88, 195 Unit 2 - Amendment No. 446,.:t-+-5, 183

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying that on a control room emergency ventilation test signal (High Radiation and/or Safety Injection test signal), the system automatically switches into a recirculation and makeup air filtration mode of operation with flow through the HEPA filters and charcoal adsorber banks of the cleanup and makeup units;

3) Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program; and

4) Verifying that the makeup filter unit heaters dissipate 4.5 +/- 0.45 kW when tested in accordance with ANSI N510-1980.

f. After each complete or partial replacement of a HEPA filter bank, by verifying that the HEPA filter bank satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.05% in accordance with ANSI N510-1980 for a DOP test aerosol while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm + 10% for the makeup units; and

g. After each complete or partial replacement of a charcoal adsorber bank, by verifying that the charcoal adsorber bank satisfies the in-place penetration and bypass leakage testing acceptance criteria of less than 0.10% in accordance with ANSI N51 0-1980 for a halogenated hydrocarbon refrigerant test gas while operating the system at a flow rate of 6000 cfm +/- 10% for the cleanup units and 1000 cfm + 10% for the makeup units.

SOUTH TEXAS - UNITS 1 & 2 3/47-18 Unit 1 - Amendment No. 7, 88,161,182,185,195 Unit 2 - Amendment No. 75, 151, 169, 172, 183

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 195 AND 183 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 to the U.S. Nuclear Regulatory Commission (NRC) dated June 28,2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML101870102), STP Nuclear Operating Company (STPNOC, the licensee), requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Units 1 and 2. The proposed changes would revise TS 3.7.7, "Control Room Makeup and Cleanup Filtration System," to add shutdown actions if the required actions for an inoperable control room envelope (CRE) boundary are not met, consistent with TS Task Force (TSTF) Standard Technical Specification change traveler TSTF-448, "Control Room Habitability," Revision 3. The purpose of the proposed change is to correct an oversight in a previous license amendment request 1 incorporating TSTF-448, Revision 3, by adding shutdown actions if the required actions for an inoperable CRE boundary specified by TS 3.7.7.d are not met.

The proposed changes also add a note to the required action for an inoperable CRE boundary to clarify that the boundary is not a required system, subsystem, train, component, or device that depends on a diesel generator as a source of emergency power. The licensee stated that the requested change clarifies the application of TS ACTION 3.8.1.1.d., "AC. Sources, D.C.

Sources, and Onsite Power Distribution," when the CRE boundary is inoperable.

2.0 REGULATORY EVALUATION

In Appendix A, "General Design Criteria [(GDC)] for Nuclear Power Plants," to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, GDC 19, "Control room," states, in part, that:

A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.

Donohew, J. N., U.S. Nuclear Regulatory Commission, letter to E. Halpin, STP Nuclear Operating Company, "South Texas Project, Units 1 and 2 - Issuance of Amendments Re: Adoption of Technical SpeCifications Task Force (TSTF) Traveler No. TSTF-448, Revision 3, 'Control Room Envelope Habitability' (TAC Nos. MD5942 and MD5943)," dated July 29,2008 (ADAMS Accession No. ML082040560).

Enclosure 3

-2 Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposure in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

TSTF-448, Revision 3, "Control Room Habitability", is a proposal to establish more effective and appropriate action, surveillance, and administrative standard TS requirements related to ensuring the habitability of the CRE.

The NRC's regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36, "Technical specifications," which requires that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TSs.

The NRC staff evaluated the requested amendment based on the licensee's assessment of the impact of the proposed changes to the STPNOC design basis analysis and the guidance of TSTF-448, Revision 3. In addition, the staff's review also ensures continued compliance with the requirements of GDC 19 and 10 CFR 50.36, as supplemented by Sections 6.4, "Control Room Habitability System," and 9.4.1, "Control Room Area Ventilation System," of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition."

3.0 TECHNICAL EVALUATION

3.1 Proposed TS Change to TS 3.7.7, "Control Room Makeup and Cleanup Filtration System" The current TS 3.7.7 states, 3.7.7 Three independent Control Room Makeup and Cleanup Filtration Systems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4:

ACTION:

a. With one Control Room Makeup and Cleanup Filtration System inoperable for reasons other than condition d, within 7 days restore the inoperable system to OPERABLE status or apply the requirements of the CRMP [Configuration Risk Management

- 3 Program], or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With two Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least two systems to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With three Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

d. One or more Control Room Makeup and Cleanup Filtration Systems inoperable due to inoperable Control Room Envelope (CRE) boundary perform the following:

1) immediately initiate action to implement mitigating actions, and

2) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months verify mitigating actions ensure CRE occupant exposure to radiological, chemical and smoke hazards will not exceed limits, and

3) within 90 days restore CRE boundary to OPERABLE status.

The revised TS 3.7.7 would state (changes in boldface):

3.7.7 Three independent Control Room Makeup and Cleanup Filtration Systems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4:

ACTION:

a. With one Control Room Makeup and Cleanup Filtration System inoperable for reasons other than condition d, within 7 days restore the inoperable system to OPERABLE status or apply the requirements of the CRMP [Configuration Risk Management Program], or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With two Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months restore at least two systems to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY

-4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c. With three Control Room Makeup and Cleanup Filtration Systems inoperable for reasons other than condition d, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months restore at least one system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

Note The Control Room Envelope (CRE) boundary is not a required system, subsystem, train, component, or device that depends on a diesel generator as a source of emergency power.

Specification 3.S.1.1.d need not be applied for an inoperable Control Room Makeup and Cleanup Filtration System that is inoperable solely due to an inoperable Control Room Envelope boundary.

d. One or more Control Room Makeup and Cleanup Filtration Systems inoperable due to inoperable Control Room Envelope (CRE) boundary perform the following:

1) Immediately initiate action to implement mitigating actions, and

2) within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months verify mitigating actions ensure CRE occupant exposure to radiological, chemical and smoke hazards will not exceed limits, and

3) within 90 days restore CRE boundary to OPERABLE status.

OR be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

There are no requested changes to the associated surveillance requirements and none granted under this amendment request.

3.2 NRC Staff Evaluation STPNOC submitted a license amendment request by letter dated June 26, 2007 (ADAMS Accession No. ML071870252), to revise the TS regarding CRE Habitability in accordance with TSTF-448, Revision 3. The NRC approved the amendment request by letter dated July 29, 2008 (ADAMS Accession No. ML082040595). However, due to an oversight, STPNOC did not provide for shutdown actions if the required actions for an inoperable CRE boundary are not met, as described by TSTF-448, Revision 3. The purpose of this amendment request is to add the shutdown requirements to ACTION d. of TS 3.7.7 to be consistent with TSTF-448, Revision 3. Currently, TS 3.0.3 would apply if the actions specified by TS 3.7.7 could not be

- 5 met. This proposed change only corrects the previous omission in order to conform to TSTF-448, Revision 3. The proposed change has already been evaluated by the NRC staff in the safety evaluation approving TSTF-448, Revision 3, and the licensee has stated that the justifications presented in the TSTF safety evaluation are applicable to STP, Units 1 and 2.

Therefore, the NRC staff concludes that the proposed change is acceptable.

The proposed amendment also adds the following note to TS 3.7.7, ACTION d:

The Control Room Envelope (CRE) boundary is not a required system, subsystem, train, component, or device that depends on a diesel generator as a source of emergency power. Specification 3.8.1.1.d need not be applied for an inoperable Control Room Makeup and Cleanup Filtration System that is inoperable solely due to an inoperable Control Room Envelope boundary.

The purpose of the note is to clarify that in those situations when the Control Room Makeup and Cleanup Filtration Systems are inoperable solely because the CRE boundary is inoperable, TS 3.8.1.1.d does not apply. The CRE boundary is not a required system, subsystem, train, component, or device that depends on a diesel generator as a source of emergency power.

Hence, TS ACTION 3.8.1.1.d will be satisfied in that with one standby diesel generator inoperable, all required systems, subsystems, trains, components, and devices that depend on the remaining OPERABLE diesel generators as a source of emergency power are also to be considered OPERABLE for the plant configuration where the CRE heating, ventilation, and air conditioning systems are inoperable only because the CRE boundary is inoperable. This prevents unnecessarily restricting plant operation where the subsystem (Le., CRE boundary) does not depend on a diesel generator as a source of emergency power. The NRC staff notes that it is not necessary to change TS ACTION 3.8.1.1.d because the added note serves to clarify an existing condition and does not change the TS nor its intent. The NRC staff concludes that this is an administrative change and, therefore, the requested change is 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 ENVIROI\IMENTAL 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 57529). 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: Harold Walker Date: Apr; 1 25, 2011

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, IRAI Balwant K. Singal, 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. 195 to NPF-76

2. Amendment No. 183 to NPF-80

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

PUBLIC RidsNrrDssScvb Resource LPLIV Reading RidsNrrPMSouthTexas Resource RidsAcrsAcnw_MailCTR Resource RidsNrrLAJBurkhardt Resource Ridsl\lrrDirsltsb Resource RidsOgcRp Resource RidsNrrDorlDpr Resource RidsRgn4MailCenter Resource RidsNrrDorlLpl4 Resource HWalker, NRRIDSS/SCVB ADAMS Accession No. ML110950146 --

Memo dated 2/2/11

~~~J;~;L~~:.~~~i~:;~~;~~L~J OFFICE NRR/LPL4/PM NRR/LPL4/LA DIRSIITSB/BC DSS/S NAME BSingal JBurkhardt RElliott RDenni DATE 4/11/11 4/7111 4/11/11 2/2111

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OFFICIAL RECORD COpy

v t e Letter Sequence Approval
TAC:ME4198, Control Room Habitability (Approved, Closed) TAC:ME4199, Control Room Habitability (Approved, Closed)
Initiation Request, Request Acceptance Administration Questions Answers Results Approval Other:
MONTHYEAR2010-06-28 [Table View]

ML110950146

Text

SUBJECT:

Dear Mr. Halpin:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

6.0 CONCLUSION

Enclosures:

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