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| | number = ML12264A320 | | | number = ML12264A320 |
| | issue date = 10/11/2012 | | | issue date = 10/11/2012 |
| | title = South Texas Project, Units 1 and 2 - Meeting Handout for 10/11/12 Pre-licensing Meeting License Amendment Request to Revise the Fire Protection Program (TAC Nos. ME9182 and ME9183) | | | title = Meeting Handout for 10/11/12 Pre-licensing Meeting License Amendment Request to Revise the Fire Protection Program |
| | author name = Taplett K | | | author name = Taplett K |
| | author affiliation = South Texas Project Nuclear Operating Co | | | author affiliation = South Texas Project Nuclear Operating Co |
| | addressee name = Singal B K | | | addressee name = Singal B |
| | addressee affiliation = NRC/NRR/DORL/LPLIV | | | addressee affiliation = NRC/NRR/DORL/LPLIV |
| | docket = 05000498, 05000499 | | | docket = 05000498, 05000499 |
| | license number = NPF-076, NPF-080 | | | license number = NPF-076, NPF-080 |
| | contact person = Singal B K | | | contact person = Singal B |
| | case reference number = TAC ME9182, TAC ME9183 | | | case reference number = TAC ME9182, TAC ME9183 |
| | document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs | | | document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs |
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| {{#Wiki_filter:Pre-licensing Meeting for License AmendmentRequesttoRevise Amendment Request to Revise the Fire Protection Program at the South Texas ProjectOctober11,2012 October 11, 2012 1 Agenda Agenda*Introductions*PurposeBkd*B ac k groun d*Fire Protection Program Change | | {{#Wiki_filter:Pre-licensing Meeting for License Amendment Request to Revise the Fire Protection Program at the South Texas Project October 11, 2012 1 |
| *BasesofChange
| | |
| *Bases of Change*Additional Information to be Developed | | Agenda |
| *Summar y y*Questions 2 | | * Introductions |
| SouthTexasProject(STP)Representatives South Texas Project (STP) Representatives*Mike Murray -Manager, Regulatory Affairs
| | * Purpose |
| *KenTaplett | | * B k Background d |
| -LicensingEngineer Ken Taplett Licensing Engineer*Frank Cox -Fire Safe Shutdown Engineer
| | * Fire Protection Program Change |
| *Charles Albur y -Thermal-H y draulic Anal y sis Su p erviso r yyyp*Donald Rohan -Operations Procedure Writer -Responsible for plant off-normal procedures in response to fire | | * Bases of Change |
| -PreviouslylicensedasaSeniorReactorOperator 3 Previously licensed as a Senior Reactor Operator Purpose PurposeDescribe the STP Nuclear O p eratin g Com p an y p ro p osal pgpyppto revise the South Texas Project, Units 1 and 2, Fire Protection Program 4 | | * Additional Information to be Developed |
| | * Summaryy |
| | * Questions 2 |
| | |
| | South Texas Project (STP) Representatives |
| | * Mike Murray - Manager, Regulatory Affairs |
| | * Ken Taplett - Licensing Engineer |
| | * Frank Cox - Fire Safe Shutdown Engineer |
| | * Charles Alburyy - Thermal-Hydraulic y Analysis y Supervisor p |
| | * Donald Rohan - Operations Procedure Writer |
| | - Responsible for plant off-normal procedures in response to fire |
| | - Previously licensed as a Senior Reactor Operator 3 |
| | |
| | Purpose Describe the STP Nuclear Operating p g Company p yp proposal p |
| | to revise the South Texas Project, Units 1 and 2, Fire Protection Program 4 |
|
| |
|
| ===Background=== | | ===Background=== |
| Background*The change involves revising the STP Licensing Basis ftithlttihtdbilit f or mee ti ng th e a lt erna tive s h u td own capa bilit y.*STP is required by their licensing basis to meet the itf10CFR50AdiRStiIIIL requ i remen t s o f 10 CFR 50 , A ppen di x R , S ec ti on III.L , Alternative and dedicated shutdown capability.STPiscurrentlyrelyingoncompensatorymeasuresto
| | * The change involves revising the STP Licensing Basis f meeting for ti the th alternative lt ti shutdown h td capability. |
| *STP is currently relying on compensatory measures to meet their licensing basis. | | bilit |
| *STPrecentlywithdrewalicenseamendmentrequest
| | * STP is required by their licensing basis to meet the requirements i t off 10 CFR 50 50, A Appendix di RR, S Section ti III III.L, L |
| *STP recently withdrew a license amendment request because insufficient information was provided to the NRC staff to approve the amendment request. | | Alternative and dedicated shutdown capability. |
| 5 FireProtectionProgramChange Fire Protection Program Change*In order to meet the regulatory requirements of Appendix R, Section III.L, the proposed amendment request:-Credits the performance of operator actions in the control room, in addition to tripping the reactor, prior to evacuation due to a fire fire. -Credit the automatic trip of the main turbine in response to a reactortrip reactor trip.6 BasesofChange Bases of Change*Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, usuallycreditsareactortrippriortocontrolroomevacuation usually credits a reactor trip prior to control room evacuation | | * STP is currently relying on compensatory measures to meet their licensing basis. |
| .In order to credit additional control room actions:Thlitdttthtibfd
| | * STP recently withdrew a license amendment request because insufficient information was provided to the NRC staff to approve the amendment request. |
| -Th e li censee mus t d emons t ra t e th e ac ti ons can b e per f orme d-The licensee should ensure that such actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire.-The licensee should consider one spurious actuation to occur before tlfthltihidthhthlttidditd con t ro l o f th e p l an t i s ac hi eve d th roug h th e a lt erna ti ve or d e di ca t e d shutdown system. *Both (1) the loss of offsite power and (2) maintainin g offsite p ower ()p()gpscenarios should be considered.*Automatic functions of circuits in the control room fire should not be creditedifthefunctionwouldmitigatetheconsequences 7 credited if the function would mitigate the consequences | | 5 |
| .
| | |
| BasesforChange(continued)
| | Fire Protection Program Change |
| Bases for Change (continued)*The feasibility and reliability of the additional operator actions have been demonstrated.*A single spurious actuation analysis demonstrates that no single spurious actuation could negate a control room actioninmannerthatAppendixR,SectionIII.L action in manner that Appendix R, Section III.L requirements are not met. | | * In order to meet the regulatory requirements of Appendix R, Section III.L, the proposed amendment request: |
| *Theautomaticturbinetripanalysisprovidesreasonable
| | - Credits the performance of operator actions in the control room, in addition to tripping the reactor, prior to evacuation due to a fire. |
| *The automatic turbine trip analysis provides reasonable assurance that the turbine will trip when actuated by a reactor trip and would not subsequently be negated by a fireinducecircuitfailure 8 fire-induce circuit failure. | | fire |
| BasesforChange(continued)
| | - Credit the automatic trip of the main turbine in response to a reactor trip trip. |
| Bases for Change (continued)*Defense-in-De p th Anal y sis addresses the py following: | | 6 |
| -FirePreventionMeasures Fire Prevention Measures-Capability to detect, control and extinguish fires-Protection of structures, systems and components so thatfireswillnotpreventsafeshutdown that fires will not prevent safe shutdown-Safety margin analyses*Analysis for those actions with small time margins shows the plantcanachievesafeshutdownconditionswhen plant can achieve safe shutdown conditions when considering instrument uncertainties.*Analysis to justify plant safe shutdown is achievable in event all the requested actions are not completed. | | |
| 9 Additional InformationtbDld t o b e D eve l ope dAddress the following scenario: | | Bases of Change |
| -S p urious actuation of p ressurizer p owe r-o p erated relief valve ppp p (PORV), and | | * Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, usually credits a reactor trip prior to control room evacuation evacuation. |
| -Pressurizer PORV block valve cannot be closed due to fire-induced circuit failure, and | | In order to credit additional control room actions: |
| -No actions credited in the c ontrol room other than manual reactor trip and automatic turbine trip, and | | - Th The licensee li mustt d demonstrate t t th the actions ti can bbe performed f d |
| -Loss of offsite p ower. 10 p Additional InformationtbDld t o b e D eve l ope d*Scenario will address the following:-Ability to maintain and/or restore natural circulation-Impact on sub-cooling marginItflitit-I mpac t on f ue l i n t egr it y 11 AddiilIfi Addi t i ona l I n f ormat i on to be DevelopedAddthittltll | | - The licensee should ensure that such actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire. |
| *Add ress th e i mpac t on reac t or vesse l wa t er l eve l for a spuriously opened steam generator PORV.*Address the impact of a control room fire on the initiationofsafetyinjection. | | - The licensee should consider one spurious actuation to occur before control t l off the th plant l t is i achieved hi d th through h ththe alternative lt ti or ddedicated di t d shutdown system. |
| initiation of safety injection. | | * Both ((1)) the loss of offsite power p and ((2)) maintaining g offsite p power scenarios should be considered. |
| 12 Summary Summary*License Amendment Request will be resubmitted Requestapprovalofsameoperatoractionsandautomatic | | * Automatic functions of circuits in the control room fire should not be credited if the function would mitigate the consequences consequences. |
| -Request approval of same operator actions and automatic turbine trip as the previously withdrawn request.-Bases for approval are the actions can be performed and that theactions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire.-Automatic turbine trip relies on success of reactor trip.-Sufficient defense-in-depth/safety margin exists to demonstrate safe shutdown conditions can be achieved based on analyses previously performed and additional information to be developed. | | 7 |
| 13 Questions? | | |
| | Bases for Change (continued) |
| | * The feasibility and reliability of the additional operator actions have been demonstrated. |
| | * A single spurious actuation analysis demonstrates that no single spurious actuation could negate a control room action in manner that Appendix R, Section III.L requirements are not met. |
| | * The automatic turbine trip analysis provides reasonable assurance that the turbine will trip when actuated by a reactor trip and would not subsequently be negated by a fire induce circuit failure fire-induce failure. |
| | 8 |
| | |
| | Bases for Change (continued) |
| | * Defense-in-Depth p Analysis y addresses the following: |
| | - Fire Prevention Measures |
| | - Capability to detect, control and extinguish fires |
| | - Protection of structures, systems and components so that fires will not prevent safe shutdown |
| | - Safety margin analyses |
| | * Analysis for those actions with small time margins shows the plant can achieve safe shutdown conditions when considering instrument uncertainties. |
| | * Analysis to justify plant safe shutdown is achievable in event all the requested actions are not completed. |
| | 9 |
| | |
| | Additional Information t be to b Developed D l d Address the following scenario: |
| | - Spurious p actuation of ppressurizer p power-operated p relief valve (PORV), and |
| | - Pressurizer PORV block valve cannot be closed due to fire-induced circuit failure, and |
| | - No actions credited in the control room other than manual reactor trip and automatic turbine trip, and |
| | - Loss of offsite p power. |
| | 10 |
| | |
| | Additional Information t be to b Developed D l d |
| | * Scenario will address the following: |
| | - Ability to maintain and/or restore natural circulation |
| | - Impact on sub-cooling margin |
| | - Impact I t on fuel f l integrity i t it 11 |
| | |
| | Additional Addi i l IInformation f i to be Developed |
| | * Add Address th the iimpactt on reactor t vessell water t llevell for a spuriously opened steam generator PORV. |
| | * Address the impact of a control room fire on the initiation of safety injection. |
| | 12 |
| | |
| | Summary |
| | * License Amendment Request will be resubmitted |
| | - Request approval of same operator actions and automatic turbine trip as the previously withdrawn request. |
| | - Bases for approval are the actions can be performed and that the actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire. |
| | - Automatic turbine trip relies on success of reactor trip. |
| | - Sufficient defense-in-depth/safety margin exists to demonstrate safe shutdown conditions can be achieved based on analyses previously performed and additional information to be developed. |
| | 13 |
| | |
| Questions? | | Questions? |
| 14}} | | 14}} |
Letter Sequence Meeting |
|---|
|
|
MONTHYEARML12243A4042012-09-25025 September 2012
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2012-11-27
[Table View] |
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2022-08-31
[Table view] |
Text
Pre-licensing Meeting for License Amendment Request to Revise the Fire Protection Program at the South Texas Project October 11, 2012 1
Agenda
- Additional Information to be Developed
South Texas Project (STP) Representatives
- Mike Murray - Manager, Regulatory Affairs
- Ken Taplett - Licensing Engineer
- Charles Alburyy - Thermal-Hydraulic y Analysis y Supervisor p
- Donald Rohan - Operations Procedure Writer
- Responsible for plant off-normal procedures in response to fire
- Previously licensed as a Senior Reactor Operator 3
Purpose Describe the STP Nuclear Operating p g Company p yp proposal p
to revise the South Texas Project, Units 1 and 2, Fire Protection Program 4
Background
- The change involves revising the STP Licensing Basis f meeting for ti the th alternative lt ti shutdown h td capability.
bilit
- STP is required by their licensing basis to meet the requirements i t off 10 CFR 50 50, A Appendix di RR, S Section ti III III.L, L
Alternative and dedicated shutdown capability.
- STP is currently relying on compensatory measures to meet their licensing basis.
- STP recently withdrew a license amendment request because insufficient information was provided to the NRC staff to approve the amendment request.
5
Fire Protection Program Change
- In order to meet the regulatory requirements of Appendix R,Section III.L, the proposed amendment request:
- Credits the performance of operator actions in the control room, in addition to tripping the reactor, prior to evacuation due to a fire.
fire
- Credit the automatic trip of the main turbine in response to a reactor trip trip.
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Bases of Change
In order to credit additional control room actions:
- Th The licensee li mustt d demonstrate t t th the actions ti can bbe performed f d
- The licensee should ensure that such actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire.
- The licensee should consider one spurious actuation to occur before control t l off the th plant l t is i achieved hi d th through h ththe alternative lt ti or ddedicated di t d shutdown system.
- Both ((1)) the loss of offsite power p and ((2)) maintaining g offsite p power scenarios should be considered.
- Automatic functions of circuits in the control room fire should not be credited if the function would mitigate the consequences consequences.
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Bases for Change (continued)
- The feasibility and reliability of the additional operator actions have been demonstrated.
- A single spurious actuation analysis demonstrates that no single spurious actuation could negate a control room action in manner that Appendix R,Section III.L requirements are not met.
- The automatic turbine trip analysis provides reasonable assurance that the turbine will trip when actuated by a reactor trip and would not subsequently be negated by a fire induce circuit failure fire-induce failure.
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Bases for Change (continued)
- Defense-in-Depth p Analysis y addresses the following:
- Fire Prevention Measures
- Capability to detect, control and extinguish fires
- Protection of structures, systems and components so that fires will not prevent safe shutdown
- Safety margin analyses
- Analysis for those actions with small time margins shows the plant can achieve safe shutdown conditions when considering instrument uncertainties.
- Analysis to justify plant safe shutdown is achievable in event all the requested actions are not completed.
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Additional Information t be to b Developed D l d Address the following scenario:
- Spurious p actuation of ppressurizer p power-operated p relief valve (PORV), and
- Pressurizer PORV block valve cannot be closed due to fire-induced circuit failure, and
- No actions credited in the control room other than manual reactor trip and automatic turbine trip, and
- Loss of offsite p power.
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Additional Information t be to b Developed D l d
- Scenario will address the following:
- Ability to maintain and/or restore natural circulation
- Impact on sub-cooling margin
- Impact I t on fuel f l integrity i t it 11
Additional Addi i l IInformation f i to be Developed
- Add Address th the iimpactt on reactor t vessell water t llevell for a spuriously opened steam generator PORV.
- Address the impact of a control room fire on the initiation of safety injection.
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Summary
- License Amendment Request will be resubmitted
- Request approval of same operator actions and automatic turbine trip as the previously withdrawn request.
- Bases for approval are the actions can be performed and that the actions cannot be negated by subsequent spurious actuation signals resulting from the postulated fire.
- Automatic turbine trip relies on success of reactor trip.
- Sufficient defense-in-depth/safety margin exists to demonstrate safe shutdown conditions can be achieved based on analyses previously performed and additional information to be developed.
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Questions?
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