ML20352A449

Changes to South Texas Project Electric Generating Station Emergency Plan

ML20352A449
Person / Time
Site:	South Texas, 07201041
Issue date:	12/17/2020
From:	Enoch J South Texas
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
NOC-AE-20003778, STI : 35106389
Download: ML20352A449 (3)

Text

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Nuclear Operating Company Sou/II Texas Project £/eclric Cener.llln,g Stal /on P.O. Bar 28;} Wadsuvrth, Texas 7748]

December 17, 2020 NOC-AE-20003778 File No.: 218 10 CFR 50.4(b)(5) 10 CFR 72.4 STI : 35106389 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 Emergency Plan In accordance with 10 CFR 50.4(b)(5) and 10 CFR 72.4, STP Nuclear Operating Company (STPNOC) hereby submits the enclosed change to the Emergency Plan. Contrary to the requirements of 10 CFR 50.54( q)(5), a letter was not submitted to the NRC regarding a change to the emergency plan by July 24, 2020 and has been captured in the South Texas Project Corrective Action Program. This letter fulfills the requirements of 10 CFR 50.54(q)(5) and 10 CFR 72.4.

These changes do not represent a reduction in effectiveness and do not require NRC approval prior to implementation in accordance with the provisions of 10 CFR 50.54(q).

There are no commitments contained within this letter.

A complete description of changes for the revised document and the summary of ana lysis are attached to this letter.

If there are any questions regarding this matter, please contact Ali Albaaj at (361) 972-8949 or me at (361) 972-8767.

~D . ~

Jtseph D. Enoch Manager, Emergency Response aa

Attachment:

Description of Changes / Summary of Analysis for Change to STPEGS EAL Technical Basis Manual cc:

Director, Division of Fuel Management Regional Adm inistrator, 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 76011-451 1 Washington, DC 20555-0001

NOC-AE-20003778 Attachment Page 1 of 2 Description of Changes / Summary of Analysis for Change to STPEGS EAL Technical Basis Manual

1. Description of Change The South Texas Project Electric Generating Station (STPEGS) Emergency Action Level (EAL)

Technical Basis Manual, Addendum 1, basis for EAL condition CU4 regarding Loss of DC Power, was revised to provide a simpler basis for users following discussions with operations personnel.

2. 10 CFR 50.54(q) Summary of Analysis Evaluation for Change The previous set of examples lead to confusion, as the attempt to provide examples for different Modes results in examples that are correct for one mode but incorrect for another. The development of precise examples for the differing modes would add unnecessary complexity and is not warranted. In replacement of the examples, a statement identifying what is meant by a required Vital DC bus and (i.e., the purpose of Vital DC in these modes) and examples of what equipment types and monitoring instruments were added. The elimination of the examples and the clarification of required Vital DC bus avoids confusion. These changes were made in alignment with NEI 99-01, Revision 6 guidance. This change does not alter the intent of the Emergency Classification Levels (ECLs), Initiating Conditions (ICs), EALs, or the Classification process.

This change does not impact the ability of the Emergency Response Organizations (ERO) ability to respond to an emergency. The organizations ability for coping with radiological emergencies will not change. The EROs overall function for ensuring the health and safety of employees and the public during an accident are not altered with this change.

The changes made in Revision 2 of the STPEGS EAL Technical Basis Manual continue to meet the following conditions, regulations, or guidance to ensure that prior approval is not needed by the NRC for these changes.

Specifically, the change:

• Does not reduce the effectiveness of the emergency plan or its implementing procedures.

• Does not reduce the capability to perform an emergency planning function.

• Continues to comply with 10 CFR Part 50.47, Emergency plans, section (b) standards.

• Continues to comply with Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities requirements.

• Continues 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-20003778 Attachment Page 2 of 2 Previous As Modified Justification Revision 1, Effective Date - November 2015 Revision 2 Addendum 1, CU4 Loss of DC Power Basis Addendum 1, CU4 Loss of DC Power Basis As used in this EAL, required means the Vital DC buses necessary As used in this EAL, required Vital DC This basis was considered to be confusing to support operation of the in-service, or operable, train or trains of Buses would be the Vital DC buses that for the user. Discussions with operations SAFETY SYSTEM equipment. If Vital DC power Train A and C are support operable trains of equipment required personnel (SROs, instructors, former SM) both lost, the ability to monitor and control cold shutdown or refueling to maintain the plant in a safe shutdown resulted in the determination that the parameters using QDPS is lost and a declaration of an UNUSUAL condition. examples will always be confusing and EVENT would be warranted. contradictory since both Modes 5 and 6 are As another example, if Train A and C are out-of-service (inoperable) The loss of these required Vital DC buses part of the EAL, and requirements for Vital for scheduled outage maintenance work and Train B is in-service would affect both remote equipment operation DC power vary. Decision was made to (operable), then a loss of Vital DC power to Train B for 15 minutes or (e.g., breaker control power) as well as remove the STP examples, as is allowed by longer would result in a loss of control of the operable SAFETY monitoring instrumentation (e.g. RHR NEI 99-01, Rev 6 guidance, and replace with SYSTEM requiring the declaration of an UNUSUAL EVENT. In this cooling, reactivity control, RCS inventory a statement identifying what is meant by a scenario, a loss of Vital DC power to Train A and/or C for 15 minutes control, RCS temperature indication, RVWL, required Vital DC bus and (i.e., the purpose or longer while Vital DC power to Train B is available, would not Pzr level, nuclear instrumentation, etc.). of Vital DC in these modes) and examples of warrant an emergency classification unless the loss of Train A and/or what equipment types and monitoring C Vital DC power would result in a loss of the ability to monitor or instruments.

control the cold shutdown or refueling parameters necessary for Train (CR 18-9203)

B operation.

As another example, if Train C is out-of-service (inoperable) for scheduled outage maintenance work, with Train A in standby (operable) and Train B in-service (operable), then a loss of Vital DC power to Train B would result in a loss of control of an operable SAFETY SYSTEM. However, if Train A is still operable, then declaration of an UNUSUAL EVENT is not required. In this scenario, a loss of Vital DC power to Train A for 15 minutes or longer while Vital DC power to Train B is available, would not warrant an emergency classification unless the loss of Train A would result in a loss of the ability to monitor or control the cold shutdown or refueling parameters necessary for Train B operation.