ML21105A533

Changes to South Texas Project Electric Generating Station (STPEGS) Emergency Plan

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

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Nuclear Operating Company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth. Texas 77483 -----------------~

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 Regional Administrator, Region IV Office of Nuclear Material Safety and U.S. Nuclear Regulatory Commission Safeguards 1600 East Lamar Boulevard U.S. Nuclear Regulatory Commission Arlington, TX 76011-4511 Washington, DC 20555-0001

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 Existing As Modified No. Type Revision 2 Effective Date - June 2020 Justification Revision 3 1 CHANGE Table of Contents: Table of Contents: Editorial change corresponding to the removal of 5.6 EMERGENCY CLASSIFICATION 5.6 EMERGENCY CLASSIFICATION the downgrade option as described in items LEVEL UPGRADING AND LEVEL UPGRADING AND TERMINATION below.

DOWNGRADING 2 CHANGE Revision Summary Revision Summary Deletion of previous revision summary and Clarified EAL Bases with plant & 1. Deleted the option for downgrading an insertion of current revision summary.

equipment conditions/status that warrant Emergency Classification Level.

declaration of the Unusual Event. 2. Changed EAL SU3, EAL-2 to conform to Affected ECL CU4. 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.

3 CHANGE Page 13, Step 4.2, Critical Page 13, Step 4.2, Critical Characteristics The option to downgrade an emergency Characteristics The scheme facilitates upgrading and classification is not a specific component of the The scheme facilitates upgrading and termination of the emergency classification Emergency Plan and is not required by downgrading of the emergency where necessary. regulation. Current processes and procedures classification where necessary. 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 Existing As Modified No. Type Revision 2 Effective Date - June 2020 Justification Revision 3 4 CHANGE Page 16: Page 16: See justification, change #3 5.6 EMERGENCY CLASSIFICATION 5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND LEVEL UPGRADING AND DOWNGRADING TERMINATION An ECL may be downgraded when When the event or condition that meets an the event or condition that meets the IC and EAL no longer exists, and other highest IC and EAL no longer exists, site-specific requirements are met, the and other site-specific downgrading ECL may be terminated.

requirements are met. If The following approach to terminating an ECL downgrading the ECL is deemed is recommended.

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.

5 CHANGE Page 16 Table under 5.6: Page 16, Table under 5.6: See justification, change #3 ALERT - Downgrade or terminate the ALERT - Terminate the emergency in emergency in accordance with plant accordance with plant procedures.

procedures.

SITE AREA EMERGENCY with no long-term SITE AREA EMERGENCY with no plant damage - Terminate the emergency in long-term plant damage - Downgrade or accordance with plant procedures.

terminate the emergency in accordance with plant procedures.

6 CHANGE Page 116, SU3: Page 116, SU3: The change in is being made to conform to the Greater than 100/ bar µCi /gm gross Greater than 540 µCi/gm Dose Equivalent Xe- new Technical Specification for Reactor Coolant activity 133 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: Page 116, SU3, EAL-2 Selection Basis: See justification, change #6 100/ bar µCi /gm gross activity 540 µCi/gm Dose Equivalent Xe-133

NOC-AE-21003799 Attachment Page 5 of 5 Existing As Modified No. Type Revision 2 Effective Date - June 2020 Justification Revision 3 8 CHANGE Footer contents from Revision 2: Footer contents from Revision 3: Editorial Changes to reflect new revision data.

I I Rev 2 Rev 3 Includes all existing footers for all pages.