ML081270047

Response to RAI on Proposed Revision to TS Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item

ML081270047
Person / Time
Site:	South Texas
Issue date:	04/29/2008
From:	Bowman C South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-08002292, TAC MD5942, TAC MD5943
Download: ML081270047 (4)

Text

Nuclear Operating Company South Texas Project Electric Generating Station PO. B&w 289 Wadsworth, Texas 77483

/

April 29, 2008 NOC-AE-08002292 10CFR50.90 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 Response to Request for Additional Information on Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process (TAC Nos. MD5942 AND MD5943)

Reference:

Letter from Charles T. Bowman to NRC Document Control Desk dated June 26, 2007, "Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process" (NOC-AE-07002165)

In the referenced letter, the STP Nuclear Operating Company (STPNOC) submitted a license amendment request to revise Technical Specifications by incorporating TSTF-448 for control room envelope habitability. This submittal responds to NRC questions regarding this request issued on March 19, 2008.

There are no new commitments in this submittal.

If you have any questions, please call Ted Koser at 361-972-8963 or me at 361-972-7454.

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

Executed on Date /

Charles T. Bowman General Manager, Oversight tck/

Attachment:

STPNOC Response to Request for Additional Information kb2-STI: 32299110

NOC-AE-08002292 Page 2 cc:

(paper copy)

(electronic copy)

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 Richard A. Ratliff Bureau of Radiation Control Texas Department of State Health Services 1100 West 49th Street Austin, TX 78756-3189 Mohan C. Thadani Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 7 D1) 11555 Rockville Pike Rockville, MD 20852 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Mohan C. Thadani U. S. Nuclear Regulatory Commission Thad Hill Eddy Daniels Catherine Callaway Brad Porlier Staney Rostad Steve Winn NRG South Texas LP Ed Alarcon J. J. Nesrsta R. K. Temple Kevin Pollo City Public Service Jon C. Wood Cox Smith Matthews C. Kirksey City of Austin

Attachment NOC-AE-08002292 Page 1 of 2 STPNOC RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION South Texas Project Units 1 and 2 Response to Request for Additional Information on Proposed Revision to Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process TAC Nos. MD5942 AND MD5943 NRC RAI The Nuclear Regulatory Commission (NRC) staff has reviewed the STP Nuclear Operating Company (STPNOC) request dated June 26, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML071870252), for approval of an amendment to the South Texas Project, Units 1 and 2, technical specifications (TS) related to control room envelope habitability, in accordance with TS Task Force (TSTF) Traveler TSTF-448, Revision 3. The staff has determined that additional information is necessary to complete its review of the request. Please provide a response which addresses the following request for additional information questions from the Containment and Ventilation Branch.

NRC RAI 1 In Section 2.2, page 1 of 5 of Attachment 1 to your letter dated June 26, 2007 (NOC-AE-07002165), it is stated that "STPNOC proposes to reference NEI [Nuclear Energy Institute] 99-03, Revision 0, dated June 2001, in the TS basis for TS 3.7.7, instead of Revision 1, dated March 2003 because the NRC has not formally endorsed Revision 1."

The staff understands this to mean that because the NRC has not endorsed Revision 1, STPNOC will not reference this document at any point. However, in Section 6.8.3.p.3, page 3 of 5 of Attachment 2, you identified under item 1) a general exception to Section C of Regulatory Guide (RG) 1.197, Revision 0, by stating that "Section 4.3.2 "Periodic CRH

[Control Room Habitability] Assessment" from NEI 99-03 Revision 1 will be used as input to a site specific Self Assessment procedure." Please clarify this inconsistency, keeping in

• mind that the NRC has neither formally endorsed NEI 99-03, Revision 1 nor has it reviewed this document.

STP Response To correct this inconsistency, STPNOC plans to withdraw the requested general exception to section C of Regulatory Guide (RG) 1.197, Revision 0, identified as item 1 in Section 6.8.3.p.3.

No other changes are being proposed to the submittal by this letter.

Attachment NOC-AE-08002292 Page 2 of 2 NRC RAI 2 In Section 2.2, page 2 of 5 (second paragraph) of Attachment 2, it is stated that "[n]o inleakage test is required to determine unfiltered in-leakage from hazardous chemical since this would be a value much less than that currently assumed in the hazardous chemical analyses." Note that NRC RG 1.197 refers to RG 1.78 for guidance on meeting a hazardous chemical challenge. -In general, the staff finds it acceptable for licensees to commit to the guidance of RG 1.78 to address hazardous chemical challenges. In the discussion you provided to address chemical hazardous challenges, it is not clear that you are in agreement with the staff position on this issue. Please provide a discussion indicating that your position is consistent with the staff position as outlined in RG 1.78, or provide justification for the differences.

STP Response Technical Specification Amendments 76 and 65, dated July 6, 1995, relocated TS 3/4.3.3.7, Chemical Detection Systems, to the Technical Requirements Manual. A subsequent design change evaluation allowed removal of the Toxic Gas monitors.

As the following excerpt from South Texas Project UFSAR section 6.4.4.2, "Toxic Gas Protection", indicates, STPNOC's position is in compliance with RG 1.78.

The habitability of the control room was evaluated using the procedures described in Regulatory Guide 1.78. As indicated in Section 2.2, no offsite storage or transport of chemicals is considered a hazard to the plant based on the Offsite Toxic Gas Analysis (Ref. 2.2-3). There are no onsite chemicals that pose a credible hazard based on the Onsite Toxic Gas Analysis (Ref. 2.2-3). Therefore, special provisions for protection against toxic gases are not required. In accordance with the plant emergency plans and procedures, self-contained breathing apparatus is provided for assurance of control room habitability.

Toxic gases which are handled onsite are kept to a minimum. During normal operation small amounts of chlorine are handled within the site boundary at the Training facility.

The amount of chlorine (<300 lbs) will not impact the control room envelope. A detailed evaluation of potential hazardous chemical accidents and their impact on control room habitability is provided in Section 2.2.3.

Reference 2.2-3 in the UFSAR lists Offsite Toxic Gas Analysis, NC 9006 Onsite Toxic Gas Analysis, NC 9015 Because there is no credible threat of hazardous chemical challenge, as defined by the procedures described in RG 1.78, testing for hazardous chemical in-leakage at STP is not required.