ML21105A533
| ML21105A533 | |
| Person / Time | |
|---|---|
| Site: | South Texas, 07201041  |
| Issue date: | 04/15/2021 |
| From: | Enoch J South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-21003799 | |
| Download: ML21105A533 (6) | |
Text
April 15, 2021 NOC-AE-21003799 File No.: Z18 10 CFR 50.4(b)(5) 10 CFR 50.54(q)(5) 10 CFR 72.4 10 CFR 72.44(f)
STI: 35155311 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498; STN 50-499; 72-1041 Changes to South Texas Project Electric Generating Station (STPEGS) Emergency Plan In accordance with 10 CFR 50.4(b)(5), 10 CFR 50.54(q)(5), 10 CFR 72.4, and 10 CFR 72.44(f), STP Nuclear Operating Company (STPNOC) hereby submits the attached change to the Emergency Plan. The change, which revises the STPEGS Emergency Action Level Technical Bases Document, became effective March 18, 2021.
STPNOC has evaluated this change in accordance with 10 CFR 50.54(q) and determined that the change does not represent a reduction in the effectiveness of the Emergency Plan and that the plan, as changed, continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. A complete description of changes and a 10 CFR 50.54(q)(5) summary for the change is attached.
There are no commitments contained within this letter.
If there are any questions regarding this matter, please contact Tim Hammons at (361) 972-7347 or me at (361) 972-8767.
Joseph D. Enoch Manager, Emergency Response tjh
Attachment:
Description of Changes and Summary of Analysis for Change to STPEGS EAL Technical Bases Document in Revision 3 cc:
Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth. Texas 77483 -----------------~
NOC-AE-21003799 Attachment Page 1 of 5 Description of Changes and Summary of Analysis for Change to STPEGS EAL Technical Bases Document in Revision 3
- 1. Description of Change Changes were made to remove the term downgrading and replace with termination. This change is considered a non-intent, non-technical change to better align with site specific processes and procedures.
Changes were made to Emergency Action Level (EAL) SU3.
The revised EAL-2 reads:
Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
Greater than 1µCi/gm Dose Equivalent I-131 OR Greater than 540 µCi/gm Dose Equivalent Xe-133 A corresponding change is being made to the SU3 EAL-2 Selection Basis.
The accompanying table displays the original text, the modified text, and the justification for each change.
- 2. 10 CFR 50.54(q) Summary of Analysis Evaluation for Change The change made to remove the term downgrading and replace with termination is considered a non-intent, non-technical change to better align with site specific processes and procedures. The proposed change is not an entire scheme change. The technical basis of the NRC approved Emergency Classification EAL scheme has not been altered. The option to downgrade an emergency classification is not a specific component of the Emergency Plan and is not required by regulation. Current processes and procedures provide for exiting a declared emergency via termination or entry into recovery as conditions require. The downgrading of an emergency classification level, once the emergency plan has been activated, provides no additional benefit or protection to the public. This change ensures the termination process is used instead of the downgrade option. The substitution of the termination process in place of the downgrade option does not result in a reduction in effectiveness.
The changes made to EAL SU3 do alter the methodology for implementation of the Emergency Classification EAL scheme. This revision was to update an EAL numeric threshold to reflect an approved change in a Technical Specification. The change continues to comply with guidance and methodologies in NEI 99-01, Revision 6.
Specifically, the changes:
- Do not reduce the effectiveness of the emergency plan or its implementing procedures.
- Do not reduce the capability to perform an emergency planning function.
- Continue to comply with 10 CFR Part 50.47, Emergency plans, section (b) standards.
NOC-AE-21003799 Attachment Page 2 of 5
- Continue to comply with Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities requirements.
- Continue to meet the elements in NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.
- 3. Change The following table displays the original text, the modified text, and the justification for the change.
NOC-AE-21003799 Attachment Page 3 of 5 No.
Type Existing Revision 2 Effective Date - June 2020 As Modified Revision 3 Justification 1
CHANGE Table of Contents:
5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND DOWNGRADING Table of Contents:
5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND TERMINATION Editorial change corresponding to the removal of the downgrade option as described in items below.
2 CHANGE Revision Summary Clarified EAL Bases with plant &
equipment conditions/status that warrant declaration of the Unusual Event.
Affected ECL CU4.
Revision Summary
- 1. Deleted the option for downgrading an Emergency Classification Level.
- 2. Changed EAL SU3, EAL-2 to conform to the new Technical Specification for Reactor Coolant System specific activity as granted by Tech Spec 3/4.4.8 change LAR in AE-NOC-20003282.
Deletion of previous revision summary and insertion of current revision summary.
3 CHANGE Page 13, Step 4.2, Critical Characteristics The scheme facilitates upgrading and downgrading of the emergency classification where necessary.
Page 13, Step 4.2, Critical Characteristics The scheme facilitates upgrading and termination of the emergency classification where necessary.
The option to downgrade an emergency classification is not a specific component of the Emergency Plan and is not required by regulation. Current processes and procedures provide for exiting a declared emergency plan implementation via termination or entry into recovery as conditions require. The downgrading of an emergency classification level, once the emergency plan has been activated, provides no additional benefit or protection to the public. This change ensures the termination process is exchanged for the downgrade option. The removal of the downgrade option does not result in a reduction in effectiveness.
NOC-AE-21003799 Attachment Page 4 of 5 No.
Type Existing Revision 2 Effective Date - June 2020 As Modified Revision 3 Justification 4
CHANGE Page 16:
5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND DOWNGRADING An ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated.
The following approach to downgrading or terminating an ECL is recommended.
Page 16:
5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND TERMINATION When the event or condition that meets an IC and EAL no longer exists, and other site-specific requirements are met, the ECL may be terminated.
The following approach to terminating an ECL is recommended.
See justification, change #3 5
CHANGE Page 16 Table under 5.6:
ALERT - Downgrade or terminate the emergency in accordance with plant procedures.
SITE AREA EMERGENCY with no long-term plant damage - Downgrade or terminate the emergency in accordance with plant procedures.
Page 16, Table under 5.6:
ALERT - Terminate the emergency in accordance with plant procedures.
SITE AREA EMERGENCY with no long-term plant damage - Terminate the emergency in accordance with plant procedures.
See justification, change #3 6
CHANGE Page 116, SU3:
Greater than 100/ bar µCi /gm gross activity Page 116, SU3:
Greater than 540 µCi/gm Dose Equivalent Xe-133 The change in is being made to conform to the new Technical Specification for Reactor Coolant System specific activity as granted by Tech Spec 3.4.8 change LAR in AE-NOC-20003282.
7 CHANGE Page 116, SU3, EAL-2 Selection Basis:
100/ bar µCi /gm gross activity Page 116, SU3, EAL-2 Selection Basis:
540 µCi/gm Dose Equivalent Xe-133 See justification, change #6
NOC-AE-21003799 Attachment Page 5 of 5 No.
Type Existing Revision 2 Effective Date - June 2020 As Modified Revision 3 Justification 8
CHANGE Footer contents from Revision 2:
Rev 2 Footer contents from Revision 3:
Rev 3 Editorial Changes to reflect new revision data.
Includes all existing footers for all pages.
I I