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Category:Letter type:NOC
MONTHYEARNOC-AE-240040, Application for Order Consenting to Direct Transfer of Licenses2024-07-31031 July 2024 Application for Order Consenting to Direct Transfer of Licenses NOC-AE-240040, Operator Licensinq Examination Schedule Revision 32024-05-15015 May 2024 Operator Licensinq Examination Schedule Revision 3 NOC-AE-240040, Relief Request Number RR-ENG-4-07 – Request for an Alternative to ASME Code Case N-729-6 for Reactor Vessel Head Penetration 752024-04-0606 April 2024 Relief Request Number RR-ENG-4-07 – Request for an Alternative to ASME Code Case N-729-6 for Reactor Vessel Head Penetration 75 NOC-AE-240040, Financial Assurance for Decommissioning - 2024 Update2024-03-28028 March 2024 Financial Assurance for Decommissioning - 2024 Update NOC-AE-240040, Unit L & 2, Supplement to Modify the Implementation Date for License Amendment Request to Revise Alternate Source Term Dose Calculation2024-02-0808 February 2024 Unit L & 2, Supplement to Modify the Implementation Date for License Amendment Request to Revise Alternate Source Term Dose Calculation NOC-AE-230040, Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06)2023-12-14014 December 2023 Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06) NOC-AE-230039, Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/20230032023-12-12012 December 2023 Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/2023003 NOC-AE-230039, Submittal of Update Foreign Ownership, Control or Influence (FOCI)2023-07-11011 July 2023 Submittal of Update Foreign Ownership, Control or Influence (FOCI) NOC-AE-220039, Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program Revision 252023-02-0606 February 2023 Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program Revision 25 NOC-AE-220038, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Cask2022-06-23023 June 2022 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Cask NOC-AE-210038, Submittal of Operations Quality Assurance Plan Changes QA-089, QA-091, and Revision 252022-01-0404 January 2022 Submittal of Operations Quality Assurance Plan Changes QA-089, QA-091, and Revision 25 NOC-AE-21003858, 10 CFR 50.46 Thirty-Day Report of Significant ECCS Model Changes2021-12-0606 December 2021 10 CFR 50.46 Thirty-Day Report of Significant ECCS Model Changes NOC-AE-21003853, Revised Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material2021-12-0303 December 2021 Revised Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material NOC-AE-21003848, Unit 1 Cycle 24 Core Operating Limits Report2021-11-18018 November 2021 Unit 1 Cycle 24 Core Operating Limits Report NOC-AE-21003846, Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material2021-11-0404 November 2021 Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material NOC-AE-21003842, 10 CFR 50.59 Summary Report2021-09-23023 September 2021 10 CFR 50.59 Summary Report NOC-AE-21003841, Request for Relief from ASME Section Xl Code Requirements for Weld Examinations (Relief Request RR-ENG-3-25)2021-09-23023 September 2021 Request for Relief from ASME Section Xl Code Requirements for Weld Examinations (Relief Request RR-ENG-3-25) NOC-AE-21003832, Supplement to License Amendment Request to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections2021-09-0909 September 2021 Supplement to License Amendment Request to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections NOC-AE-21003812, Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections2021-08-10010 August 2021 Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube Inspections NOC-AE-21003825, Update of Foreign Ownership, Control, or Influence Information (FOCI)2021-08-0505 August 2021 Update of Foreign Ownership, Control, or Influence Information (FOCI) NOC-AE-21003824, Update Foreign Ownership, Control, or Influence (FOCI)2021-07-29029 July 2021 Update Foreign Ownership, Control, or Influence (FOCI) NOC-AE-21003823, Update Foreign Ownership Control or Influence (FOCI)2021-07-28028 July 2021 Update Foreign Ownership Control or Influence (FOCI) NOC-AE-21003820, Nuclear Insurance Protection2021-07-20020 July 2021 Nuclear Insurance Protection NOC-AE-21003819, Inservice Inspection Summary Report - 2RE212021-07-15015 July 2021 Inservice Inspection Summary Report - 2RE21 NOC-AE-21003816, Commitment Change Summary Report2021-06-30030 June 2021 Commitment Change Summary Report NOC-AE-21003814, Technical Specification Bases Control Program2021-06-24024 June 2021 Technical Specification Bases Control Program NOC-AE-21003810, Update Foreign Ownership, Control, or Influence (FOCI)- CPS Energy2021-06-17017 June 2021 Update Foreign Ownership, Control, or Influence (FOCI)- CPS Energy NOC-AE-21003811, Update Foreign Ownership, Control, or Influence (FOCI)- Nrg Energy2021-06-17017 June 2021 Update Foreign Ownership, Control, or Influence (FOCI)- Nrg Energy NOC-AE-21003806, Inservice Inspection Program Plan and Inservice Testing Program Snubber Inservice Test Plan for the Fourth Ten-Year Interval2021-05-20020 May 2021 Inservice Inspection Program Plan and Inservice Testing Program Snubber Inservice Test Plan for the Fourth Ten-Year Interval NOC-AE-21003801, Annual Dose Report for 20202021-04-26026 April 2021 Annual Dose Report for 2020 NOC-AE-21003802, 2020 South Texas Project Electric Generating Station Annual Environmental Operating Report2021-04-26026 April 2021 2020 South Texas Project Electric Generating Station Annual Environmental Operating Report NOC-AE-21003804, Operator Licensing Examination Schedule2021-04-21021 April 2021 Operator Licensing Examination Schedule NOC-AE-21003800, Radioactive Effluent Release Report2021-04-19019 April 2021 Radioactive Effluent Release Report NOC-AE-21003799, Changes to South Texas Project Electric Generating Station (STPEGS) Emergency Plan2021-04-15015 April 2021 Changes to South Texas Project Electric Generating Station (STPEGS) Emergency Plan NOC-AE-21003795, Cycle 22 Core Operating Limits Report2021-04-15015 April 2021 Cycle 22 Core Operating Limits Report NOC-AE-21003796, Update Foreign Ownership, Control, or Influence (FOCI)2021-04-15015 April 2021 Update Foreign Ownership, Control, or Influence (FOCI) NOC-AE-21003790, Response to Apparent Violations in NRC Inspection Report 05000498/2020401 and 05000499/2020401: (EA-20-122) (Letter)2021-03-31031 March 2021 Response to Apparent Violations in NRC Inspection Report 05000498/2020401 and 05000499/2020401: (EA-20-122) (Letter) NOC-AE-21003791, Financial Assurance for Decommissioning - 2021 Update2021-03-31031 March 2021 Financial Assurance for Decommissioning - 2021 Update NOC-AE-210037, STP Fire Hazards Analysis Report, Amendment 26 (Redacted)2021-03-30030 March 2021 STP Fire Hazards Analysis Report, Amendment 26 (Redacted) NOC-AE-21003792, STP Fire Hazards Analysis Report, Amendment 26 (Redacted)2021-03-30030 March 2021 STP Fire Hazards Analysis Report, Amendment 26 (Redacted) NOC-AE-200037, License Amendment Request to Revise Technical Specification 3.6.3 to Append a Note and Remove the Index from Technical Specifications2021-03-11011 March 2021 License Amendment Request to Revise Technical Specification 3.6.3 to Append a Note and Remove the Index from Technical Specifications NOC-AE-21003784, Response to Request for Additional Information Regarding 1RE22 Inspection Summary Report for Steam Generator Tubing2021-03-0808 March 2021 Response to Request for Additional Information Regarding 1RE22 Inspection Summary Report for Steam Generator Tubing NOC-AE-21003786, Annual Fitness for Duty Performance Report for 20202021-03-0101 March 2021 Annual Fitness for Duty Performance Report for 2020 NOC-AE-21003785, Evidence of Financial Protection2021-02-23023 February 2021 Evidence of Financial Protection NOC-AE-21003781, Notice Regarding Withdrawal of Funds from Nuclear Decommissioning Trust Subaccounts2021-01-27027 January 2021 Notice Regarding Withdrawal of Funds from Nuclear Decommissioning Trust Subaccounts NOC-AE-21003780, Submittal of Update Foreign Ownership, Control, or Influence (FOCI)2021-01-0707 January 2021 Submittal of Update Foreign Ownership, Control, or Influence (FOCI) NOC-AE-20003778, Changes to South Texas Project Electric Generating Station Emergency Plan2020-12-17017 December 2020 Changes to South Texas Project Electric Generating Station Emergency Plan NOC-AE-20003777, STPNOC Concerns Regarding the Proposed Change to the Evaluated Force-on-Force Inspection Guidance During the COVID-19 Public Health Emergency2020-12-10010 December 2020 STPNOC Concerns Regarding the Proposed Change to the Evaluated Force-on-Force Inspection Guidance During the COVID-19 Public Health Emergency NOC-AE-20003766, Supplement to Change Implementation Date for License Amendment Request to Revise the STPEGS Emergency Plan2020-12-0202 December 2020 Supplement to Change Implementation Date for License Amendment Request to Revise the STPEGS Emergency Plan NOC-AE-20003767, Request for a One-Time Exemption from 10 CFR 73, Appendix 8, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic2020-11-16016 November 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix 8, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic 2024-07-31
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Nuclear Operating Company South TewasPromect Electric Generatn Station, PO. Box 289 Wadsworth. Tebas 77483 -
May 28, 2008 NOC-AE-08002291 10CFR50.36 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Clarification of the Applicability of Risk Managed Technical Specifications to Technical Specification 3.7.7
References:
- 1. Letter dated Decembler 28, 2006, from David W. Rencurrel, STPNOC, to NRC Document Control Desk, "Revised Broad Scope Risk-Informed Technical Specification Amendment Request" (ML070040247, NOC-AE-06002036, TAC Nos. MD2341 & MD2342)
- 2. Letter dated July 13, 2007, from Mohan C. Thadani, NRC, to James J. Sheppard, STPNOC, "South Texas Project, Units I and 2 - Issuance of Amendments Re: Broad-Scope Risk-Informed Technical Specifications Amendments (TAC Nos. MD234i and MD2342)" (ML071780186, ML071780191)
In Reference 1, the STP Nuclear Operating Company (STPNOC) submitted a revised license amendment request for a broad scope risk-informed set of Technical Specification (TS) changes. The proposed amendment was approved in Reference 2 with the issuance of Amendment 179 and Amendment 166 to the STP Unit I and Unit 2 operating licenses, respectively. STPNOC is submitting this letter to correct a statement in Reference 1 with respect to the application of Risk Managed Technical Specification (RMTS) to Technical Specification (TS) 3.7.7, "Control Room Makeup and Cleanup Filtration System" and to clarify how RMTS is to apply to TS 3.7.7. The incorrect statement resulted in the potential for a noncompliance with the basis for the license amendment, but had no potential to significantly affect safety.
Background and
Description:
On July 13, 2007, Amendments 179 and 166 to the TS approved the RMTS to allow the Configuration Risk Management Program (CRMP) to be applied to various STP TS for extending ACTION times for inoperable trains. The amendment permitted the CRMP to be applied to TS 3.7.7 on a limited basis.
The Control Room Makeup and Cleanup Filtration System (CRMCFS), commonly referred to as Control Room HVAC (CRHVAC), includes a recirculation and filtration function that maintains the design basis accident radiation dose to the operators within the limits of General Design Criteria 19. The system also provides required cooling for the operators and equipment. The dose mitigation function is not modeled in the STP Probabilistic Risk Assessment (PRA) because it is evaluated as having no impact on core STI: 32298143
NOC-AE-08002291 Page 2 damage frequency (CDF) or large early release frequency (LERF), which are the metrics for application of RMTS. The cooling function is modeled. Based on discussion with the NRC reviewers, it was determined during the license amendment application review that the dose mitigation function could not be included in the scope of RMTS because it is not modeled in the PRA.
At the time the amendment was approved, STPNOC believed the dose mitigation function was independent of the cooling function and the CRMP could be applied to TS 3.7.7 for conditions where only the cooling function is affected. The "limited" basis approved in the license amendment allows the CRMP to apply to conditions where only the cooling function of the CRHVAC is affected. Reference I addressed this by stating that the wording below would be included in the TS Bases for TS 3.7.7, and the TS Bases were changed accordingly.
"The dose mitigation function governed by TS 3.7.7 does not depend on the cooling function governed by TS 3.7.7 that is supported by TS 3.7.14 for EchW. Therefore, if a TS 3.7.7 action applies because EchW is not available or the cooling coil for CRHVAC is not operable, the provision to apply the CRMP may be used."
During a review of the basis for application of RMTS in February 2008, STPNOC determined that at least one train of Essential Chilled Water (EchW) supported by Essential Cooling Water (EW) is required to maintain humidity to support achieving the filter efficiency assumed in the accident dose analysis. Based on this information, the dose mitigation function governed by TS 3.7.7 has some dependence on the cooling function and the statement above is not correct.
The discrepancy in the information was entered in the STPNOC Corrective Action Program and administrative restrictions were put in place to prevent the use of RMTS for CRHVAC. STPNOC has not applied RMTS to TS 3.7.7. The discrepancy had the potential to result in a noncompliance with the' licensing basis for the approval of the amendment; however, because of the low risk significance of the dose mitigation function, it had no potential to significantly affect safety.
Clarification of Applicability of RMTS to TS 3.7.7:
STP TS 3.7.7 requires the operability of three independent trains of CRHVAC. The required actions of TS 3.7.7 are shown below.
- a. With one Control Room Makeup and Cleanup Filtration System inoperable, within 7 days restore the inoperable system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- b. With two Control Room Makeup and Cleanup Filtration Systems inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> restore at least two systems to OPERABLE status or apply the requirements of the CRMP, or be at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
- c. With three Control Room Makeup and Cleanup Filtration Systems inoperable, suspend all operations involving movement of spent fuel, and crane operation with loads over the spent fuel pool, and within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> restore at least one system to OPERABLE status or apply the requirements of the CRMP, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
NOC-AE-08002291 Page 3 In response to the discrepancy described above, STPNOC performed a calculation that determined that two trains of CRHVAC pressurization (fans) with one train of cooling is adequate for the dose mitigation function based on maintaining the required control room envelope positive pressure and maintaining the relative humidity of the control room air below the 70% acceptance criteria required to support design basis assumptions for carbon filter efficiency. The calculation shows that with a train of CRHVAC in TS 3.7.7 Action a for loss of cooling (i.e., the associated train of EW or EChW is inoperable), either of the two operable trains of CRHVAC provides adequate cooling to maintain the filter efficiency for the CRHVAC system to perform its design function to mitigate dose. STPNOC concluded that the system is capable of meeting its dose mitigation function in this configuration. Therefore, application of the CRMP to TS 3.7.7 Action a for one train of CRHVAC inoperable because it cannot perform its cooling function is permissible in accordance with the Bases for the TS.
For TS 3.7.7 Action b or Action c, application of the CRMP would be to extend the time to restore the required redundancy for the unmodeled dose mitigation function and is not allowed.
STPNOC has revised the Bases for TS 3.7.7 to allow application of the CRMP only to TS 3.7.7 Action a.
Follow-up Actions:
STPNOC plans to submit a license amendment request to permit unrestricted application of RMTS to TS 3.7.7 by October 2, 2008.
There are no commitments in this letter.
If you have any questions, please call Wayne Harrison at 361-972-7298 or me at 361-972-7136.
Scott M. Head Manager, Licensing
NOC-AE-08002291 Page 4 cc:
(papercopy) (electronic copy)
Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani U. S. Nuclear Regulatory Commission Mohan C. Thadani Thad Hill Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 7 D1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN1 16 Kevin Pollo Wadsworth, TX 77483 City Public Service C. M. Canady Jon C. Wood City of Austin Cox Smith Matthews Electric Utility Department.
721 Barton Springs Road C. Kirksey Austin, TX 78704 City of Austin Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189