ML12264A320

Meeting Handout for 10/11/12 Pre-licensing Meeting License Amendment Request to Revise the Fire Protection Program

ML12264A320
Person / Time
Site:	South Texas
Issue date:	10/11/2012
From:	Taplett K South Texas
To:	Balwant Singal Plant Licensing Branch IV
Singal B
References
TAC ME9182, TAC ME9183
Download: ML12264A320 (14)

Text

Pre-licensing Meeting for License Amendment Request to Revise the Fire Protection Program at the South Texas Project October 11, 2012 1

Agenda

• Introductions

• Purpose

• B k Background d

• Fire Protection Program Change

• Bases of Change

• Additional Information to be Developed

• Summaryy

• Questions 2

South Texas Project (STP) Representatives

• Mike Murray - Manager, Regulatory Affairs

• Ken Taplett - Licensing Engineer

• Frank Cox - Fire Safe Shutdown Engineer

• Charles Alburyy - Thermal-Hydraulic y Analysis y Supervisor p

• Donald Rohan - Operations Procedure Writer

- Responsible for plant off-normal procedures in response to fire

- Previously licensed as a Senior Reactor Operator 3

Purpose Describe the STP Nuclear Operating p g Company p yp proposal p

to revise the South Texas Project, Units 1 and 2, Fire Protection Program 4

Background

• The change involves revising the STP Licensing Basis f meeting for ti the th alternative lt ti shutdown h td capability.

bilit

• STP is required by their licensing basis to meet the requirements i t off 10 CFR 50 50, A Appendix di RR, S Section ti III III.L, L

Alternative and dedicated shutdown capability.

• STP is currently relying on compensatory measures to meet their licensing basis.

• STP recently withdrew a license amendment request because insufficient information was provided to the NRC staff to approve the amendment request.

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Fire Protection Program Change

• In order to meet the regulatory requirements of Appendix R,Section III.L, the proposed amendment request:

- Credits the performance of operator actions in the control room, in addition to tripping the reactor, prior to evacuation due to a fire.

fire

- Credit the automatic trip of the main turbine in response to a reactor trip trip.

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Bases of Change

• Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, usually credits a reactor trip prior to control room evacuation evacuation.

In order to credit additional control room actions:

- Th The licensee li mustt d demonstrate t t th the actions ti can bbe performed f d

- The licensee should ensure that such actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire.

- The licensee should consider one spurious actuation to occur before control t l off the th plant l t is i achieved hi d th through h ththe alternative lt ti or ddedicated di t d shutdown system.

• Both ((1)) the loss of offsite power p and ((2)) maintaining g offsite p power scenarios should be considered.

• Automatic functions of circuits in the control room fire should not be credited if the function would mitigate the consequences consequences.

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Bases for Change (continued)

• The feasibility and reliability of the additional operator actions have been demonstrated.

• A single spurious actuation analysis demonstrates that no single spurious actuation could negate a control room action in manner that Appendix R,Section III.L requirements are not met.

• The automatic turbine trip analysis provides reasonable assurance that the turbine will trip when actuated by a reactor trip and would not subsequently be negated by a fire induce circuit failure fire-induce failure.

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Bases for Change (continued)

• Defense-in-Depth p Analysis y addresses the following:

- Fire Prevention Measures

- Capability to detect, control and extinguish fires

- Protection of structures, systems and components so that fires will not prevent safe shutdown

- Safety margin analyses

• Analysis for those actions with small time margins shows the plant can achieve safe shutdown conditions when considering instrument uncertainties.

• Analysis to justify plant safe shutdown is achievable in event all the requested actions are not completed.

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Additional Information t be to b Developed D l d Address the following scenario:

- Spurious p actuation of ppressurizer p power-operated p relief valve (PORV), and

- Pressurizer PORV block valve cannot be closed due to fire-induced circuit failure, and

- No actions credited in the control room other than manual reactor trip and automatic turbine trip, and

- Loss of offsite p power.

10

Additional Information t be to b Developed D l d

• Scenario will address the following:

- Ability to maintain and/or restore natural circulation

- Impact on sub-cooling margin

- Impact I t on fuel f l integrity i t it 11

Additional Addi i l IInformation f i to be Developed

• Add Address th the iimpactt on reactor t vessell water t llevell for a spuriously opened steam generator PORV.

• Address the impact of a control room fire on the initiation of safety injection.

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Summary

• License Amendment Request will be resubmitted

- Request approval of same operator actions and automatic turbine trip as the previously withdrawn request.

- Bases for approval are the actions can be performed and that the actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire.

- Automatic turbine trip relies on success of reactor trip.

- Sufficient defense-in-depth/safety margin exists to demonstrate safe shutdown conditions can be achieved based on analyses previously performed and additional information to be developed.

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Questions?

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