NOC-AE-11002675, Day Response to NRC Bulletin 2011-01, Mitigating Strategies

Day Response to NRC Bulletin 2011-01, Mitigating Strategies

ML11165A095
Person / Time
Site:	South Texas
Issue date:	06/08/2011
From:	Bowman C South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002675
Download: ML11165A095 (5)

Text

Nuclear Operating Company South Taws Pro/ect Electric GeneratingStat/on PC. Sox 289 Wadsworth, Texas 77483 -

June 8, 2011 NOC-AE-1 1002675 10 CFR 50.54(f)

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 No. STN 50-498, STN 50-499 30-Day Response to NRC Bulletin 2011-01, Mitigating Strategies Pursuant to 10 CFR 50.54(f), this letter provides the STP Nuclear Operating Company (STPNOC) 30-day response to NRC Bulletin 2011-01, "Mitigating Strategies," dated May 11, 2011. The bulletin was issued to confirm continued compliance with 10 CFR 50.54(hh)(2) and request information regarding the mitigation strategies programs.

The NRC identified the following three objectives:

1. To require that addressees provide a comprehensive verification of their compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.54(hh)(2),

2. To notify addressees about the NRC staff's need for information associated with licensee mitigating strategies under 10 CFR 50.54(hh)(2) in light of the recent events at Japan's Fukushima Daiichi facility in order to determine if 1) additional assessment of program implementation is needed, 2) the current inspection program should be enhanced, or 3) further regulatory action is warranted, and

3. To require that addressees provide a written response to the NRC in accordance with 10 CFR 50.54(f).

NRC Bulletin 2011-01 requested that within 30 days, licensees submit a response to questions to confirm continued compliance with 10 CFR 50.54(hh)(2) and requested within 60 days that licensees provide information regarding mitigation strategies programs required by 10 CFR 50.54(hh)(2). STPNOC's 30-day response is provided in the attachment.

There are no commitments in this letter.

STI: 32869469

NOC-AE-1 1002675 Page 2 of 3 If you have questions regarding this letter please contact either Robyn Savage (Licensing contact) at 361-972-7438 or me at 361-972-7454.

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

Executed on _ /. e, 2-0Ži Charles T. Bowman General Manager Nuclear Safety Assurance rds

Attachment:

30-Day Response to Bulletin 2011-01

NOC-AE-1 1002675 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 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Catherine Callaway U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8B1) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Ed Alarcon Senior Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Richard Pena P. 0. Box 289, Mail Code: MN1 16 City Public Service Wadsworth, TX 77483 C. M. Canady 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 Texas Department of State Health Services Alice Rogers Texas Department of State Health Services

Attachment NOC-AE-1 1002675 Page 1 of 2 30-Day Response to Bulletin 2011-01 The NRC has requested the following information:

In order to confirm continued compliance with 10 CFR 50.54(hh)(2), within 30 days of the date of this bulletin, the NRC requests that licensees provide the following information on their mitigating strategies programs.

NRC Request 1 Is the equipment necessary to execute the mitigatingstrategies,as describedin your submittals to the NRC, available and capable of performing its intended function?

STPNOC Response (1)

STPNOC inspected and inventoried equipment necessary to implement the mitigating strategies required by 10 CFR 50.54 (hh)(2) and verified it was available. In addition, the portable pump required for some of the strategies as well as the station's three (3) permanently installed fire pumps were tested to ensure they were capable of performing their intended function with respect to the mitigation strategies. Letters of Agreement/Memorandums of Understanding with offsite organizations were also re-validated and/or re-issued, as appropriate.

NRC Request 2 Are the guidance and strategiesimplemented capable of being executed consideringthe current configurationof your facility and current staffing and skill levels of the staff?

STPNOC Response (2) 10 CFR 50.54 (hh)(2) requires licensees to implement guidance and strategiesunder the circumstances associated with loss of large areas of the plant due to explosions or fire, in the following areas:

(I) Fire fighting; (ii) Operationsto mitigate fuel damage; and (iii) Actions to minimize radiologicalrelease.

STPNOC verified that the mitigation strategies associated with large area fires and explosions are available and capable of being performed as described in our Mitigation Strategy License Condition. Each procedure implementing the required mitigation strategies was walked down to ensure the procedure(s) are in place and capable of being implemented. The mitigation strategies have been maintained. STPNOC's mitigation strategies continue to meet the commitments described in our B.5.b submittals as documented in the B.5.b Safety Evaluation Report - SER (See Reference 1), except those changes made to the strategies since the issuance of STPNOC's Safety Evaluation Report. These changes have been evaluated and documented in accordance with NEI 99-04, "Guidelines for Managing NRC Commitment

Attachment NOC-AE-1 1002675 Page 2 of 2 30-Day Response to Bulletin 2011-01 Changes (Rev. 0) and continue to meet the requirements of NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline (Rev. 2).

STPNOC is capable of executing the strategies with the current staffing. As discussed above, each procedure implementing the required mitigation strategies was walked down to ensure the procedures were in place and capable of being implemented. In developing the strategies STPNOC considered staffing and skill levels in order to perform the strategies. Operations and support staff have had training and periodic retraining, as required, on the mitigation strategies procedures.

In the event of certain threats, plant personnel are directed to disperse in accordance with procedures to maximize the survivability in order to implement the strategies should they be needed. Procedures identify the command and control responsibilities including succession, as appropriate. Procedures are in place to call back fire brigade /security/emergency response organization members (through an automated dialing system) to assure adequate staffing in the event of a large fire or explosion.

Reference 1: South Texas Project Units 1 and 2 - Conforming License Amendments to Incorporate The Mitigation Strategies Required by Section B.5.b. of Commission Order EA 026 TAC Nos. MD4639 AND MD4640, dated July 11, 2007 (AE-NOC-07001653)