ML12297A331
| ML12297A331 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/27/2012 |
| From: | Balwant Singal Plant Licensing Branch IV |
| To: | Plant Licensing Branch IV |
| Singal B | |
| References | |
| TAC ME9182, TAC ME9183 | |
| Download: ML12297A331 (19) | |
Text
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November 27, 2012 LICENSEE:
STP Nuclear Operating Company FACILITY:
South Texas Project, Units 1 and 2
SUBJECT:
SUMMARY
OF OCTOBER 11, 2012, PRE*L1CENSING PUBLIC MEETING WITH STP NUCLEAR OPERATING COMPANY TO DISCUSS THE PROPOSED LICENSE FOR APPROVAL OF THE REVISED FIRE PROTECTION PROGRAM RELATED TO THE ALTERNATE SHUTDOWN CAPABILITY DOCUMENTED IN THE FIRE HAZARDS ANALYSIS (TAC NOS. ME9182 AND ME9183)
On October 11,2012, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC), and representatives of STP Nuclear Operating Company (STPNOC, the licensee) at NRC Headquarters, Rockville, Maryland. The meeting notice and agenda, dated September 25, 2012, is located in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML12243A404. The purpose of the meeting was to discuss the proposed license amendment request (LAR) for approval of the revised fire protection program related to the alternate shutdown capability documented in the fire hazards analysis for South Texas project (STP), Units 1 and 2.
A list of meeting attendees is provided as an Enclosure 1 to this meeting summary.
Meeting Summary The discussion included an overview of the proposed LAR for STP, Units 1 and 2, as follows:
Purpose
Background
Fire Protection Program Change Bases of Change
- Additional Information to be Developed Summary and Conclusions A copy of the meeting materials/handouts is located at ADAMS Accession No. ML12264A320.
However, the licensee made minor changes to the handout materials provided in advance and distributed a revised handout during the meeting. A copy of the revised handout is provided as enclosure 2 to this meeting summary.
Results of Discussions The licensee was requested by the NRC staff to include a matrix or table of all the considerations and potential combinations of various considerations evaluated in support of the proposed LAR in the formal submittal for sake of clarity.
- 2 The NRC staff suggested that the proposed LAR should not have high reliance on thermal-hydraulics analysis for defense-in-depth. Other deterministic tools, such as fire modeling, may offer better success path for defense-in-depth.
However, if the licensee chooses to rely on thermal-hydraulics for defense-in depth, a clear and concise discussion of why the thermal-hydraulic analysis is bounding needs to be provided.
The licensee needs to provide a detailed uncertainty analysis and define the acceptance criteria used for the purpose of the evaluation.
The NRC staff requested that the licensee describe the human factors evaluation performed in support of the proposed LAR as it relates to the proposed control room actions before evacuating the control room. As an example. the NRC staff cited the evaluation performed in support of extended power uprates.
The licensee confirmed that the proposed LAR will be based on deterministic approach and will not use the risk-informed approach.
The licensee stated that it intends to submit the proposed LAR by March 2013 and may request another pre-licensing meeting prior to the submittal.
No Public Meeting Feedback Forms were received for this meeting.
Please direct any inquiries to me at (301) 415-3016, or balwant.singal@nrc.gov.
Sincerely.
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Bal:ant K. Singal, Set/ior 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. List of Attendees
- 2. Revised Handout cc w/encl: Distribution via Listserv
LIST OF ATTENDEES OCTOBER 11, 2012. MEETING WITH STP NUCLEAR OPERATING COMPANY REGARDING PROPOSED LICENSE AMENDMENT REQUEST FOR APPROVAL OF REVISED FIRE PROTECTION PROGRAM RELATED TO THE ALTERNATE SHUTDOWN CAPABILITY SOUTH TEXAS PROJECT. UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 NAME TITLE ORGANIZATION Ken T applett Licensing Engineer STP Nuclear Operating Company (STPNOC) i i
Roland Dunn Manager, Nuclear Fuel and Analysis STPNOC Frank Cox Safe Shutdown Supervising Engineer STPNOC Charles Albury Thermal Hydraulic Analysis Supervisor STPNOC Michael Murray Manager. Regulatory Affairs STPNOC Donald Rohan Operations Procedures STPNOC Kaly Kalyanam Project Manager U.S. Nuclear Regulatory Commission (NRC)
J. Hyslop Senior Risk Reliability Engineer NRC Harry Barrett Senior Fire Protection Engineer NRC i Gary Cooper Fire Protection Engineer NRC Brian Metzler Fire Protection Engineer NRC Daniel Frumkin Team Leader. Fire Protection Group NRC Donnie Harrison Branch Chief. PRA Licensing Branch NRC J
Kamishan Martin Human Factors Engineer NRC Carmen Franklin Human Factor Engineer NRC Ben Parks*
Reactor Systems Engineer NRC Steve Alferink*
Reactor Inspector NRC. Region IV Craig Peterson*
CSA Inc.
R obert Layton
- Pacific Northwest National Laboratory
- Participated via phone I
I
Pre-licensing Meeting for License Amendment Request to Revise the Fire Protection Program at the South Texas Project October 11, 2012 1
Agenda
- I ntrod uctions
- Purpose
- Background
- Fire Protection Program Change
- Bases of Change
- Additional Information to be Developed
- Summary
- Questions 2
Representatives
- Mike Murray - Manager, Regulatory Affairs
- Roland Dunn - Manager, Nuclear Fuels &Analysis
- Ken Taplett - Licensing Engineer
- Frank Cox - Fire Safe Shutdown Engineer
- Charles Albury - Thermal-Hydraulic Analysis Supervisor
- 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 Company proposal to revise the South Texas Project, Units 1 and 2, Fire Protection Program 4
=
Background===
- The change involves revising the STP Licensing Basis for meeting the alternative shutdown capability.
- STP is required by the licensing basis to meet the requirements of 10 CFR 50, Appendix R, Section III.L, Alternative and dedicated shutdown capability.
- STP is currently relying on compensatory measures to meet the licensing basis.
- STP recently withdrew a license amendment request because insufficient information was provided to the NRC staff to approve the amendment request.
5
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.
Credit the automatic trip of the main turbine in response to a reactor trip.
6
Bases of Change
- Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, usually credits a reactor trip prior to control room evacuation.
In order to credit additional control room actions:
- The licensee must demonstrate the actions can be performed 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 of the plant is achieved through the alternative or dedicated shutdown system.
- Both (1) the loss of offsite power and (2) maintaining offsite 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.
7
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-induced circuit failure.
8
Bases for Change (continued)
- Defense-in-Depth Analysis 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.
9
Thermal Hydraulic Defense-in-Depth Analyses
- Assumes no operator actions other than reactor trip are performed in the control prior to evacuation.
- Assumes automatic functions because of control room/relay room separation.
- Four cases analyzed Spurious opening of bank of steam dump valves Spurious opening of one pressurizer PORV Spurious opening of pressurizer spray valve Spurious opening of feedwater regulating valve
- Following requirements met to achieve safe shutdown after control transferred to alternative shutdown stations Pressurizer level returns to indicating range Steam generator level returns to indication range Reactor Coolant System boration reactivity control restored 10
Additional Information to be Developed Address the following scenario:
Spurious actuation of pressurizer power-operated 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 power.
11
Additional Information to be Developed
- Scenario will address the following:
- Ability to maintain and/or restore natural circulation
- Impact on sub-cooling margin
- Impact on fuel integrity 12
Additional Information to be Developed
- Address the impact on reactor vessel water level for a spuriously opened steam generator PORV.
- Address the impact of a.control room fire on the initiation of safety injection.
13
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.
14
3 ummary ML12297A331 NRRlLPL4/PM OFFICE NRRlLPL4/PM NRRllPl4/LA INRRlDRAlAHPB/BC INRRlDSSlSRXBlBC NAME BSingal Flyon for
.IBurkhardt IUShoop kson KKalyanam
- DATE 11/5112 10/25/12
- 11/5/12 112 10/25/12 NRRlDRAlAFPB/BC NRRlDRAlAPLAlBC NRRlLPL4/BC INRRllPl4/PM OFFICE AKlein i DHarrison MMarkley
!BSingal (AWang for)
NAME DATE 11/5/12 11/1112 11/27/12 111/27/12