ML14352A180

NRR E-mail Capture - Request for Additional Information (RAI) - Revised Emergency Action Levels for South Texas Project, Units 1 and 2 (TACs MD4195 and MF4196)

ML14352A180
Person / Time
Site:	South Texas
Issue date:	12/18/2014
From:	Balwant Singal Plant Licensing Branch IV
To:	Sterling L South Texas
References
TAC MF4195, TAC MF4196
Download: ML14352A180 (6)

Text

NRR-PMDAPEm Resource From: Singal, Balwant Sent: Thursday, December 18, 2014 9:01 AM To: Lsterling@stpegs.com

Subject:

Request for Additional Information (RAI) - Revised Emergency Action Levels for South Texas Project, Units 1 and 2 (TACs MD4195 and MF4196)

Attachments: MF4195-EAL-RAI.docx By letter dated May 15, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML14164A341), STP Nuclear Operating Company (the licensee) requested approval for an emergency action level scheme change for the South Texas Project, Units 1 and 2.

The NRC staff requires additional information described in the attachment to this e-mail to complete its review of the request. Draft request for additional information (RAI) was transmitted via e-mail on November 25, 2014. A clarification call was held on December 16, 2014. The licensee agreed to provide the response to the RAI by January 30, 2015. Please treat this e-mail as formal transmittal of RAIs.

Balwant K. Singal Senior Project Manager (Comanche Peak, STP, and Palo Verde)

Nuclear Regulatory Commission Division of Operating Reactor Licensing Balwant.Singal@nrc.gov Tel: (301) 415-3016 Fax: (301) 415-1222 1

Hearing Identifier: NRR_PMDA Email Number: 1780 Mail Envelope Properties (192BB59294514E41B5305C3C828676080169C71E04E5)

Subject:

Request for Additional Information (RAI) - Revised Emergency Action Levels for South Texas Project, Units 1 and 2 (TACs MD4195 and MF4196)

Sent Date: 12/18/2014 9:01:28 AM Received Date: 12/18/2014 9:01:00 AM From: Singal, Balwant Created By: Balwant.Singal@nrc.gov Recipients:

"Lsterling@stpegs.com" <Lsterling@stpegs.com>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 954 12/18/2014 9:01:00 AM MF4195-EAL-RAI.docx 35987 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: ZZZ

REQUEST FOR ADDITIONAL INFORMATION SOUTH TEXAS PROJECT, UNITS 1 AND 2 LICENSE AMENDMENT REQUEST FOR EMERGENCY ACTION LEVEL SCHEME CHANGE DOCKET NUMBERS 50-498 AND 499 By letter dated May 15, 2014 (AgencyWide Documents Access and Management System (ADAMS) Accession Number ML14164A341), STP Nuclear Operating Company (STPNOC, the licensee) requested approval for an emergency action level (EAL) scheme change for the South Texas Project Units 1 and 2 (STP).

In the letter, the licensee stated that its current scheme is based on Nuclear Management and Resources Council / National Environmental Studies Project-007 (NUMARC/NESP-007),

Revision 2, Methodology for Development of Emergency Action Levels, (ADAMS Accession No. ML041120174), which was found to be acceptable for use as generic EAL development guidance by the U.S. Nuclear Regulatory Commission (NRC) staff by letter dated August 31, 1992 (ADAMS Accession No. ML030440044).

STPNOC proposes to change the EALs from a scheme based on NUMARC/NESP-007, Revision 2 to a scheme based on NEI 99-01, Revision 6, "Methodology for Development of Emergency Action Levels (ADAMS Accession No. ML12326A805). Such a change in scheme requires NRC approval prior to implementation. NEI 99-01, Revision 6 was found to be acceptable for use as generic EAL development guidance by the NRC staff by letter dated April 1, 2013 (ADAMS Accession No. ML12346A463).

The NRC staff requires the following additional information to complete its review of the request:

RAI-01

Because the information in the basis document can affect emergency classification decision making, NEI 99-01, Revision 6, Section 4.6 contains an expectation that the basis document will be evaluated in accordance with the provisions of Title 10 of the Code of Federal Regualtions (10 CFR), Paragraph 50.54(q). Please explain how this expectation will be clearly identified to ensure appropriate reviews are conducted for any potential changes to the basis document.

Note: The NRC staff does understand that appropriate administrative controls are in place to ensure that changes to Abnormal and Emergency Operating Procedures are screened to determine if an evaluation pursuant to 10 CFR 50.54(q) is required. This RAI is intended to ensure similar controls are in place for the STP EAL Basis Document.

2

RAI-02

The proposed Section 4.3, Instrumentation Used for EALs, was changed to include If instrumentation failures occur that have EALs associated with them (i.e., process radiation monitors) alternate means of implementation may be used as described in plant procedures.

For consistency, please use the term compensatory, rather than alternate, as it relates to means of implementation, or provide further rational for use of term alternate.

Note: Licensees are required to maintain, in effect, their Emergency Plan as stated in 10 CFR 50.54(q)(2). Since all the probable methods of compensating for instrumentation are usually too numerous to effectively analyze, licensees should make every effort to compensate for instrumentation deficiencies when they occur, and should document this compensation in their corrective action program.

RAI-03

Table R-1, Recognition Category R Initiating Condition Matrix, was not modified with site-specific information for RU1, RS2, and RG2. Please provide justification or revise accordingly.

RAI-04

The proposed EALs RU1 appears to be a different base-value than the escalation values (RA1, etc.). Please justify further or revise accordingly. If the values are correct, please note the discrepancy in the basis section.

RAI-05

The proposed EAL RU2 uses potentially confusing logic associations to determine the applicable classification. Please explain how this EAL will be consistently evaluated pending approval, or revise to add clarity regarding the logic.

RAI-06

The proposed EAL RA3.2 includes a number of plant areas for all operating modes. Please verify the plant areas identified for EAL RA3.2 reflect only those areas required for normal plant operations, cooldown, or shutdown, and that access to these areas is required, i.e., cannot be operated remotely. Please provide evidence of this verification, or revise as necessary to support accurate and timely assessment. In addition, consider adding operating mode specificity to the listed areas if applicable.

RAI-07

The proposed EAL CU1.1 uses the term reactor vessel flange to identify the threshold.

However, Operating Mode 6 technical specifications may allow Reactor Coolant System (RCS) level below the flange under certain controlled conditions. Please justify further the deviation from the endorsed guidance or revise accordingly.

3

RAI-08

The proposed EAL CS1 uses a level that is less than 33% of plenum as the site-specific level for EAL declaration. This level is contrary to NRC endorsed guidance which describes the site-specific level as 6 inches below the bottom ID of the RCS loop and not the low point of the loop. Additionally, the proposed EAL CS1 does not include the conditions where containment closure is established. Please provide a justification for these deviations from NRC endorsed guidance, or revise accordingly.

RAI-09

The proposed EAL CG1 does not incorporate EAL CG1.1 from the endorsed guidance, and insufficient justification was provided for this deviation.

a. Please provide further explanation as to why this threshold was not developed, or revise accordingly to incorporate.

b. The exclusionary note, from the endorsed guidance, is important to maintain as intended to ensure consistent implementation. Please justify why it was not added, or revise accordingly.

RAI-10

The proposed Loss of RCS Barrier due to Category 3, RCS Activity / Containment Radiation, Threshold A, contains a plant-specific basis discussion where temperature induced currents as the result of an RCS leak would preclude the use of containment radiation monitors (RT-8050 and RT-8051) for approximately 40 minutes, and a secondary system break would preclude the use of the containment radiation monitors for 90 minutes.

a. Please add this information to the table as the table is the decision-maker tool used for EAL determination, or justify how this information will consistently be used by EAL decision-makers.

b. Please explain why these limitations were not included for Containment Barrier Potential Loss threshold 3.A.1, or revise accordingly.

c. Please explain why these limitations were not included for Fuel Clad Barrier Loss threshold 3.A.1, or revise accordingly.

RAI-11

The proposed HU4 EAL does not include the independent spent fuel storage installation (ISFSI) as an area of concern for EAL HU4.3 and HU4.4. Please justify further or revise accordingly.

4

RAI-12

The proposed EAL HA5 appears to cover a wide range of rooms or areas during all modes of operation.

a. Please verify the plant areas identified for EAL RA3.2 reflect only those areas required for normal plant operations, cooldown, or shutdown, and that access to these areas is required, i.e., cannot be operated remotely. Please provide evidence of this verification, or revise as necessary to support accurate and timely assessment. In addition, consider adding operating mode specificity to the listed areas if applicable.

b. For EAL HA5, please provide justification for the omission of the control room as a plant area where access is needed to support normal plant operations, cooldown, or shutdown.

RAI-13

For EALs HS6 and HG1, please consider the addition of operating mode specificity to the listed safety functions to preclude event classification when these safety functions are no longer needed in accordance with site technical specifications, or provide rational as to why this would not be appropriate.

RAI-14

For EAL SU4, please explain why consideration should be given for SU4.3. The use of 150 gallons per day may be the technical specification limit for primary-secondary leakage, but this equates to ~0.1 gallons per minute when the expectation for the Notification of Unusual Event classification is 25 gallons per minute for 15 minutes or longer. The NRC endorsed guidance allows for this value in situations where licensees do not have a specific steam generator tube leakage value applicable to the initiating condition. Please justify or revise accordingly.

RAI-15

For EAL SU5 and SA5, please provide justification for removing the basis discussion that was included in NRC approved guidance that actions taken at back panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control panels.

RAI-16

The definition of Containment Closure is expected to be the STP site-specific definition, not the generic terminology from the endorsed guidance. Please justify or revise accordingly.