ML11333A094

South Texas Project, Units 1 & 2, Clarification to Response to Request for Additional Information for License Renewal Application (TAC No. ME4938 & ME5122)

ML11333A094
Person / Time
Site:	South Texas
Issue date:	11/17/2011
From:	Rencurrel D W South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-11002761, STI: 33052689, TAC ME4938, TAC ME5122
Download: ML11333A094 (4)

Text

dLM11"/Nuclear Operating CompanySouth Texas Project Electric Generatin$ Station PO Box 289 Wadsworth. Texas 77483 -v- --November 17, 2011NOC-AE-1 100276110CFR54STI: 33052689File: G25U.S. Nuclear Regulatory CommissionAttention: Document Control DeskOne White Flint North11555 Rockville PikeRockville, MD 20852-2746South Texas ProjectUnits 1 and 2Docket Nos. STN 50-498, STN 50-499Clarification to Response to Request for Additional Information for theSouth Texas Project License Renewal Application (TAC No. ME4938 and ME5122))

References:

1. STPNOC Letter dated October 25, 2010, from G. T. Powell to NRC DocumentControl Desk, "License Renewal Application" (NOC-AE-1 0002607) (ML103010257)2. STPNOC Letter dated September 6, 2011 from G. T. Powell to NRC DocumentControl Desk, "Response to Request for Additional Information for the SouthTexas Project License Renewal Application (TAC Nos. ME4938 and ME5122)"(NOC-AE-1 1002719) (ML1 1255A21 1)By Reference 1, STP Nuclear Operating Company (STPNOC) submitted the License RenewalApplication (LRA) for South Texas Project (STP) Units 1 and 2. This letter provides additionalinformation to the response to NRC request for additional information RAI HP-1 (Reference 2).There are no regulatory commitments in this letter.Should you have any questions regarding this letter, please contact either Arden Aldridge, STPLicense Renewal Project Lead, at (361) 972-8243 or Ken Taplett, STP License Renewal Projectregulatory point-of-contact, at (361) 972-8416.I declare under penalty of perjury that the foregoing is true and correct.Executed on 11I /L/W .DateSenior Vice President,Technical Support & OversightKJT

Enclosure:

Clarification to STPNOC Response to Requests for Additional Information NOC-AE-1 1002761Page 2cc:(paper copy)(electronic copy)Regional Administrator, Region IVU. S. Nuclear Regulatory Commission612 East Lamar Blvd, Suite 400Arlington, Texas 76011-4125Balwant K. SingalSenior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North (MS 8B1)11555 Rockville PikeRockville, MD 20852Senior Resident InspectorU. S. Nuclear Regulatory CommissionP. O. Box 289, Mail Code: MN116Wadsworth, TX 77483C. M. CanadyCity of AustinElectric Utility Department721 Barton Springs RoadAustin, TX 78704John W. DailyLicense Renewal Project Manager (Safety)U.S. Nuclear Regulatory CommissionOne White Flint North (MS 011-Fl)Washington, DC 20555-0001Tam TranLicense Renewal Project Manager(Environmental)U. S. Nuclear Regulatory CommissionOne White Flint North (MS O11F01)Washington, DC 20555-0001A. H. Gutterman, EsquireKathryn M. Sutton, EsquireMorgan, Lewis & Bockius, LLPJohn RaganCatherine CallawayJim von SuskilNRG South Texas LPKevin PolioRichard PenaCity Public ServicePeter NemethCrain Caton & James, P.C.C. MeleCity of AustinRichard A. RatliffAlice RogersTexas Department of State Health ServicesBalwant K. SingalJohn W. DailyTam TranU. S. Nuclear Regulatory Commission EnclosureNOC-AE-1 1002761Page 1 of 2SOUTH TEXAS PROJECTLICENSE RENEWAL APPLICATIONCLARIFICATION TO STPNOC RESPONSE TOREQUESTS FOR ADDITIONAL INFORMATIONChanges to the STPNOC response to the following request for additional information isprovided in line-in/line-out format.Human HealthNRC RAI HP-1:Issue:The applicant's evaluation identified five locations where the transmission lines exceeded theNational Electrical Safety Code (NESC) recommended standard of 5 milliamperes for electricshock concern. However, the environmental report (ER) does not contain a discussion of anymitigation measures being considered for the locations where the electric shock potentialexceeds the NESC standard.

Background:

As required by Title 10 of the Code of Federal Regulations (10 CFR) 51.53(c)(3)(ii)(H), Section4.13 of the STP ER contains an evaluation of the acute shock potential from the transmissionlines within the scope of license renewal. The applicant's evaluation identified five locationswhere the transmission lines exceeded the NESC recommended standard of 5 milliamperes.For these transmission lines, the applicant's ER concluded " ... that electric shock is ofMODERATE significance, because 1) there are few exceedances of the NESC standard, 2) theexceedances are a small percentage of the standard, 3) the locations of the exceedances arevery remote or on private property, and 4) the transmission service providers have not receivedany complaints about induced-current shock. Accordingly, no mitigation measures arerequired." Hence, the ER does not contain a discussion of any mitigation measures beingconsidered for the locations where the electric shock potential exceeds the NESC standard.10 CFR 51.53(c)(3)(iii) states that the ER " ... must contain a consideration of alternatives forreducing adverse impacts, as required by 10 CFR 51.45(c), for all Category 2 license renewalissues ... " 10 CFR 51.45(c) states, "The environmental report must include an analysis thatconsiders and balances the environmental effects of the proposed action, the environmentalimpacts of alternatives to the proposed action, and alternatives available for reducing oravoiding adverse environmental effects."Requested Information:Please provide additional information related to alternatives available for reducing or avoidingadverse environmental effects from those transmission lines that exceed the NESC standard.

EnclosureNOC-AE-1 1002761Page 2 of 2STPNOC response:Potential mitigation measures for reducing or avoiding adverse environmental effects fromthose transmission lines that exceed the NESC standard could include:* re-examining the induced current calculations for the selected spans,* raising the towers at the affected road-transmission line intersections,* rephasing the double-circuit lines, and/or* placing caution signs under the lines.STPNOC re-examined the induced current calculations that support Table 4.13-1 in theEnvironmental Report. The Transmission Service Providers (TSPs) provided revised sags at120 degrees for selected spans and the induced current was recalculated. In addition, one TSPcalculation is based on more recent engineering data. The re-examination resulted in the Hilljeline location and one Skyline location on a low traffic road being verified to be < 5 milliampere(ma). The two Hill Country locations and the remaining Skyline location still exceed the 5 mastandard.The configuration of two Hill country locations and the remaining Skyline location have changedsince the Final Environmental Statement for the construction permit, referenced in theEnvironmental Report, Section 3.1.3. STP no longer connects directly with the Skyline or HillCountry substations. A substation was constructed at Elm Creek. From STP the original HillCountry and Skyline transmission lines are looped into the Elm Creek substation beforeproceeding to the Hill Country and Skyline substations. (Reference UFSAR Figure 8.2-4) TheseSTIR lines arc Fe configured and now stop at Elm Creek Substation.No mitigation is required as stated in the Environmental Report, Section 4.13:STPNOC's assessment under 10 CFR 51 concludes that electric shock is of MODERATEsignificance, because 1) there are few exceedances of the NESC standard, 2) theexceedances are a small percentage of the standard, 3) the locations of the exceedancesare very remote or on private property, 4) the transmission service providers have notreceived any complaints about induced-current shock. Accordingly, no mitigation measuresare required.This position is further supported by: (1) the two Hill Country lines and the one Skyline linewhere the 5 milliampere standard is exceeded are beyond the Elm Creek substation and are nolonger connected to STP; and (2) all STP transmission lines will continue to be in service afterthe STP facility is decommissioned. The Proposed Action to renew the operating licenses forSTP Units 1 and 2 has no effect on transmission lines directly connected to the STP switchyard.Therefore, under NEPA, the Proposed Action does not need further analysis.