NOC-AE-14003137, Response to Request for Additional Information on License Amendment Request for Fire Protection Program Changes

Response to Request for Additional Information on License Amendment Request for Fire Protection Program Changes

ML14149A251
Person / Time
Site:	South Texas
Issue date:	05/19/2014
From:	Gerry Powell South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-14003137, TAC MF2477, TAC MF2478
Download: ML14149A251 (7)

Text

Nuclear Operating Company South Texas Pro/ect Electric GeneratingStation PQ. Box 289 Wadsworth, Texas 77483 May 19, 2014 NOC-AE-14003137 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 License Amendment Request for South Texas Project, Units 1 and 2 Fire Protection Program Changes - Request for Additional Information TAC Nos. MF2477 and MF2478

References:

1. Letter from D.W. Rencurrel, STP Nuclear Operating Company, to NRC Document Control Desk, "License Amendment Request for Approval of a Revision to the South Texas Project Fire Protection Program Related to the Alternative Shutdown Capability," dated July 23, 2013. (NOC-AE-13002962)

(ML13212A243)

2. E-mail from B. Singal, NRC, to J. Morris, STP Nuclear Operating Company, "License Amendment Request for South Texas Project, Units 1 and 2 Fire Protection Program Changes - Request for Additional Information", TACs MF2477 and MF2478, dated April 17, 2014. (AE-NOC-14002527)

On July 23, 2013, STP Nuclear Operating Company (STPNOC) submitted a license amendment request to revise the South Texas Project Units 1 and 2 Fire Protection Program related to alternate shutdown capability (Reference 1). In the event that a fire requires evacuation of the control room, the proposed amendment requested crediting the performance of certain operator actions, including one automatic operation, prior to evacuation.

By e-mail dated April 17, 2014 (Reference 2), the NRC requested additional information related to the STPNOC amendment request. Attachment 1 provides the STPNOC response to the Requests for Additional Information (RAI).

ST 368 p STI: 33876768

NOC-AE-14003137 Page 2 of 3 There are no commitments in this letter.

If there are any questions regarding this letter, please contact Rafael Gonzales at (361) 972-4779 or me at (361) 972-7566.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on rA&16 J, ZO04 G.T. Powell Site Vice President rjg

Attachment:

1. Request for Additional Information License Amendment Request Revision to the Fire Protection Program South Texas Project, Units 1 and 2

NOC-AE-14003137 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 NRC Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Cris Eugster P. 0. Box 289, Mail Code: MN1 16 L. D. Blaylock Wadsworth, TX 77483 CPS Energy Jim Collins Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Richard A. Ratliff Robert Free Texas Department of State Health Services

Attachment 1 NOC-AE-1 4003137 ATTACHMENT 1 Request for Additional Information License Amendment Request Revision to the Fire Protection Program South Texas Project, Units 1 and 2

Attachment 1 NOC-AE-14003137 Page 1 of 3 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST REVISION TO THE FIRE PROTECTION PROGRAM SOUTH TEXAS PROJECT, UNITS 1 AND 2 Request for Additional Information:

1. Section 3.7.1 of Enclosure 1 to the application dated July 23, 2013, "Does adequate time exist to perform the proposed operator actions," states the following, in part:

"The capability to perform the operator actions following a reactor trip is assessed in the aggregate. The validation of the operator actions are timed in sequence such that the time to perform any individual action is dependent on performing the prior required action(s). Operator walk down performance data indicates that these actions can be performed in less than 90 seconds (a recent performance demonstrated that the steps were performed in 58 seconds) following initiation of the reactor trip. This meets the thermal-hydraulic analysis which requires all the actions to be completed in less than 120 seconds."

It is not clear if the time of 58-90 seconds to perform operator action is for one particular operator action or for all the actions identified in Table 1, "Proposed Operator Actions". Please provide a clear discussion if the statement applies to performance of all the actions in Table 1.

Please explain the reason for singling out one operator action, if the statement applies to only one particular operator action.

2. Note 3 to Table 1 states:

"Capability to perform the operator action is demonstrated in the aggregate. The operator actions are timed in sequence such that the time to perform any individual action is dependent on successfully performing the previous action(s)."

It is not clear from the statement if the actions are performed in parallel by multiple operators or all the actions are performed in sequence. Based on the U.S. Nuclear Regulatory Commission (NRC) staff understanding these actions are to be performed in sequence. Please provide a clear discussion.

Attachment 1 NOC-AE-1 4003137 Page 2 of 3 NRC Request- 1

1. Section 3.7.1 of Enclosure 1 to the application dated July 23, 2013, "Does adequate time exist to perform the proposed operator actions," states the following, in part:

"The capability to perform the operator actions following a reactor trip is assessed in the aggregate. The validation of the operator actions are timed in sequence such that the time to perform any individual action is dependent on performing the prior required action(s). Operator walk down performance data indicates that these actions can be performed in less than 90 seconds (a recent performance demonstrated that the steps were performed in 58 seconds) following initiation of the reactor trip. This meets the thermal-hydraulic analysis which requires all the actions to be completed in less than 120 seconds."

It is not clear if the time of 58-90 seconds to perform operator action is for one particular operator action or for all the actions identified in Table 1, "Proposed Operator Actions". Please provide a clear discussion if the statement applies to performance of all the actions in Table 1.

Please explain the reason for singling out one operator action, if the statement applies to only one particular operator action.

STPNOC Response:

Table 1, "Proposed Operator Actions", is arranged showing the eight operator actions that are performed in sequential order to meet the alternate shutdown requirements. Column three of this table titled, "Recent demonstrated time", provides a time line of the time demonstrated to perform each action by taking a cumulative series summation of the time taken to actually perform each action plus the previous actions. For example the first action (Initiate main steam isolation) took the operators 7 seconds to perform. The next action (Close both pressurizer PORV block valves) took 10 seconds to complete. By summing the first action to the second action, the total time is 17 seconds as reported in column three second row of Table 1. Please refer to the Table 1 excerpt below for additional clarification.

Fiaure 1 : Table 1 Excerpt Table 1 Proposed Operator Actions Operator Action I Credited Recent Reason for the action Licensing Basis Time 2* demonstrated Requirement 4 (seconds) time 3 (seconds)

Initiate main steam 30 7 To protect against an uncontrolled cool down of the RCS Appendix R, Section isolation in the event of a fire-induced spurious opening of a III.L.2.b.

(single switch) secondary steam-side valve such as in the steam dump F ~systemn.

Close both 60 7+10=17 To protect against an uncontrolled depressurization of Appendix R, Section pressurizer and loss of RCS inventory in the event of a fire-induced III.L.2.b PORV5 block valves spurious opening of a pressurizer PORV.

(two switches) ,

This series summation is performed for all eight actions to demonstrate that the total time required to complete all eight actions is 58 seconds.

Attachment 1 NOC-AE-14003137 Page 3 of 3 NRC Request - 2

2. Note 3 to Table 1 states:

"Capability to perform the operator action is demonstrated in the aggregate. The operator actions are timed in sequence such that the time to perform any individual action is dependent on successfully performing the previous action(s)."

It is not clear from the statement if the actions are performed in parallel by multiple operators or all the actions are performed in sequence. Based on the U.S. Nuclear Regulatory Commission (NRC) staff understanding these actions are to be performed in sequence. Please provide a clear discussion.

STPNOC Response:

The actions are performed in sequence in the order laid out in Table 1 by a single reactor operator. Once the required action has been completed, the reactor operator moves to the next action without delay. The action times in the table have been validated in a simulator scenario trained on by all the operator crews. This training includes the requirement to meet the credited time limitations identified in Table 1.