ML15055A039
| ML15055A039 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/11/2015 |
| From: | Capristo A South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NOC-AE-15003214, STI: 34039132, TAC MD4195, TAC MD4196 | |
| Download: ML15055A039 (22) | |
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Nuclear Operating CompanySouth Texas Project Electric Generatin8 Station P.. BoHa 289 Wadsworth, Texas 77483 /February 11, 2015NOC-AE-1500321410 CFR 50.90File No. G25U. S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001South Texas ProjectUnits 1 and 2Docket Nos. STN 50-498, STN 50-499Response to Request for Additional Information -South Texas Project (STP), Units 1 and 2 License Amendment Request forEmergqency Action Level Scheme Change (TACs MD4195 and MF4196)References:1. Letter; G. T. Powell to USNRC Document Control Desk; "License Amendment Requestfor Revision to Unit 1 and Unit 2 Emergency Action Levels;" NOC-AE-14003087; datedMay 15, 2014 (ML14164A341)2. E-mail; Balwant Singal to Lance Sterling; "Request for Additional Information (RAI) -Revised Emergency Action Levels for South Texas Project, Units 1 and 2 (TACsMD4195 and MF4196);" dated December 18, 2014 (ML14352A1 80)By Reference 1, STP Nuclear Operating Company (STPNOC) requested approval of a LicenseAmendment Request for revision to Unit 1 and 2 Emergency Action Levels. By Reference 2, theNRC staff requested additional information (RAI) to complete its review. STPNOC's response toReference 2 is provided in the Attachment to this letter. The No Significant HazardsConsideration determination provided in Reference 1 is not altered by the additional informationprovided in this correspondence.While formulating the attached RAI response, STPNOC discovered several discrepancies in thecalculation that was performed to determine EAL threshold values for Abnormal Rad Levels. Asa result, the STPNOC response to RAI-04 is not complete. As discussed with the Staff, after thediscrepancies are resolved, STPNOC will provide a response to RAI-04 by February 26, 2015.Included with the response to RAI-04 will be a clean copy and a redline markup copy of theSTPEGS Emergency Action Level Technical Bases Document.There are no commitments in this letter.STI: 34039132 NOC-AE-15003214Page 2 of 3If there are any questions, please contact Drew Richards at (361) 972-7666 or me at(361) 972-7697.I declare under penalty of perjury that the foregoing is true and correct.Executed onAldo CapristoExecutive Vice PresidentChief Administrative OfficerDateamrAttachment:Response to Request for Additional Information -South Texas Project (STP), Units 1 and 2License Amendment Request for Emergency Action Level Scheme Change NOC-AE-15003214Page 3 of 3cc:(paper copy)(electronic copy)Regional Administrator, Region IVU.S. Nuclear Regulatory Commission1600 East Lamar BoulevardArlington, TX 76011-4511Lisa M. RegnerSenior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint North (MS 8 G9A)11555 Rockville PikeRockville, MD 20852NRC Resident InspectorU. S. Nuclear Regulatory CommissionP.O. Box 289, Mail Code: MN116Wadsworth, TX 77483Morgan, Lewis & Bockius LLPSteve FrantzU.S. Nuclear Regulatory CommissionLisa M. RegnerNRG South Texas LPJohn RaganChris O'HaraJim von SuskilCPS EnergyKevin PolioCris EugsterL. D. BlaylockCrain Caton & James, P.C.Peter NemethCity of AustinCheryl MeleJohn WesterTexas Dept. of State Health ServicesRichard A. RatliffRobert Free
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Response to Request for Additional Information -South Texas Project(STP), Units 1 and 2 License Amendment Request for Emergency ActionLevel Scheme Change
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1NOC-AE-15003214Page 1 of 18REQUEST FOR ADDITIONAL INFORMATIONSOUTH TEXAS PROJECT, UNITS 1 AND 2LICENSE AMENDMENT REQUEST FOREMERGENCY ACTION LEVEL SCHEME CHANGEDOCKET NUMBERS 50-498 AND 499The NRC staff requires the following additional information to complete its review of the request:RAI-01Because the information in the basis document can affect emergency classification decisionmaking, NEI 99-01, Revision 6, Section 4.6 contains an expectation that the basis document willbe evaluated in accordance with the provisions of Title 10 of the Code of Federal Regulations(10 CFR), Paragraph 50.54(q). Please explain how this expectation will be clearly identified toensure appropriate reviews are conducted for any potential changes to the basis document.Note: The NRC staff does understand that appropriate administrative controls are in place toensure that changes to Abnormal and Emergency Operating Procedures are screened todetermine if an evaluation pursuant to 10 CFR 50.54(q) is required. This RAI is intendedto ensure similar controls are in place for the STP EAL Basis Document.STPNOC RESPONSE TO RAI-OlProcedure OPGP05-ZV-0010, Emergency Plan Change, provides administrative controls forevaluating changes to the STP EAL Technical Bases in accordance with 1 OCFR50.54(q). Nofurther action is required.Per OPGP05-ZV-0010, 4.1 Emergency Plan Change Process; changes shall be prepared asfollows:* The proposed change shall be reviewed using a 50.54(q) screen to determine whetheran effectiveness evaluation is required. The screen will be performed in accordance withAddendum 1 of this procedure and documented on Form 1, Screen Evaluation Form.* IF the change impacts an Emergency Action Level, conduct a review of the EAL inaccordance with Addendum 3 and document the evaluation on Form 3, EAL ChangeEvaluation Form.Per OPGP05-ZV-0010 Addendum 3, EAL Change Evaluation Instructions: "The EmergencyAction Levels and the EAL technical bases manual are a part of the Emergency Plan. Thissection is. applicable to all changes to the EALs that include changes to the technical basesmanual, initiating conditions, fission product barriers, mode applicability, bases, definitions, andother subjects necessary to establish the criteria for entering an emergency plan event."1.0 Evaluate all changes to the EAL technical bases manual in accordance with theseinstructions.2.0 Use the same CR number as on the Screen and Effectiveness Evaluations as the identifierfor the EAL evaluation for traceability of all three evaluation forms to the same change.
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1NOC-AE-15003214Page 2 of 18RAI-02The proposed Section 4.3, "Instrumentation Used for EALs," was changed to include "Ifinstrumentation failures occur that have EALs associated with them (i.e., process radiationmonitors) alternate means of implementation may be used as described in plant procedures."For consistency, please use the term "compensatory," rather than "alternate," as it relates tomeans of implementation, or provide further rational for use of term "alternate."Note: Licensees are required to maintain, in effect, their Emergency Plan as stated in10 CFR 50.54(q)(2). Since all the probable methods of compensating for instrumentationare usually too numerous to effectively analyze, licensees should make every effort tocompensate for instrumentation deficiencies when they occur, and should document thiscompensation in their corrective action program.STPNOC RESPONSE TO RAI-02STPNOC has revised the proposed Section 4.3, "Instrumentation Used for EALs" to replace theterm "alternate" with the term "compensatory" as follows:"If instrumentation failures occur that have EALs associated with them (i.e., processradiation monitors) compensatory means of implementation may be used asdescribed in plant procedures."
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1NOC-AE-15003214Page 3 of 18RAI-03Table R-1, "Recognition Category "R" Initiating Condition Matrix," was not modified with site-specific information for RU1, RS2, and RG2. Please provide justification or revise accordingly.STPNOC RESPONSE TO RAI-03STPNOC has revised Table R-1, "Recognition Category "R" Initiating Condition Matrix with sitespecific information for RU1, RS2 and RG2 as follows:RU1 Release ofgaseous or liquidradioactivity greaterthan 2 times theODCM limits for 60minutes or longer.Op. Modes: AllRS2 Spent fuel poollevel at 40'-4" or lower.Op. Modes: AllRG2 Spent fuel poollevel cannot berestored to at least40'-4" for 60 minutesor longer.Op. Modes: All
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1NOC-AE-15003214Page 4 of 18RAI-04The proposed EALs RU1 appears to be a different base-value than the escalation values (RA1,etc.). Please justify further or revise accordingly. If the values are correct, please note thediscrepancy in the basis section.STPNOC RESPONSE TO RAI-04During the development of this RAI response, STPNOC identified several discrepancies in theEAL threshold calculation for RU1, RA1, RS1, and RG1 (reference Calculation STPNOC013-CALC-002). STPNOC is tracking this item in the STP Corrective Action Program (reference CRs15-2022, 15-2576). Once these discrepancies are resolved, STPNOC will provide a response tothis RAI by February 26, 2015.
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INOC-AE-15003214Page 5 of 18RAI-05The proposed EAL RU2 uses potentially confusing logic associations to determine theapplicable classification. Please explain how this EAL will be consistently evaluated pendingapproval, or revise to add clarity regarding the logic.STPNOC RESPONSE TO RAI-0OSTPNOC has revised EAL RU2 to reduce the potentially confusing logic associations byrestructuring the multiple statements in a manner consistent with the STP Emergency OperatingProcedure User's Guide, OPOP01-ZA-0018. The individual choices for the conditions identifiedin "a" and "b" are confined to bulleted statements separated by a logical "OR" conjunction. Whenmultiple conditions are required to satisfy the criteria within the bulleted choices, theseconditions are separated by a logical "AND" conjunction.(1) a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated byANY of the following:* Visual ObservationOR* Annunciator alarm on lampbox 22M02 Window F-5 "SFP WATER LVL HI/LO"OR" Spent fuel in the ICSA AND Annunciator alarm on lampbox 22M02 WindowF-6 "SFP Trouble" AND Plant Computer point FCLC1420 "REFLNG CAV LVLIN CNTMT" (ICSA Water Level HI/LO) is in alarm.ANDb. UNPLANNED rise in area radiation levels on ANY of the following radiationmonitors.* RE-8055 (68' RCB) -Mode 5 or 6 onlyOR* RE-8099 (68' RCB) -Mode 5 or 6 onlyOR* RE-8090 (68' FHB)
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1NOC-AE-15003214Page 6 of 18RAI-06The proposed EAL RA3.2 includes a number of plant areas for all operating modes. Pleaseverify the plant areas identified for EAL RA3.2 reflect only those areas required for normal plantoperations, cooldown, or shutdown, and that access to these areas is required, i.e., cannot beoperated remotely. Please provide evidence of this verification, or revise as necessary tosupport accurate and timely assessment. In addition, consider adding operating modespecificity to the listed areas if applicable.STPNOC RESPONSE TO RAI-06STPNOC has revised EAL RA3.2 to include a listing of plant areas that require access fornormal plant operations, cooldown, or shutdown and components in these areas cannot beremotely operated. Additionally, modes of applicability have been included for each area asfollows:(2) An UNPLANNED event results in radiation levels that prohibit or impede access toANY of the areas listed in Table H3/R2.TABIE'H3/R2: Plant Areas Requirij64Ac),essOther Aux Boilers, Lighting DG, LCs 12L & 12G, IVC 44 ft all areasLU-L TGB 83ft turbine area, 55ft all areas, 29ft all open areas, Deaerator Storage Tank Stand, Cold_ Chem Lab, Feed Booster Pumps and Startup Feedwater PumpMAB Cubicle 335, Hot Chem Lab, CVCS Chemical Mixing Tank Room, Boron Analyzer Room 235A* .: " ... .." .. -P.' ". ". ..*.'.. ., %...: , .* 1 .. ...,Other Aux Boilers, Lighting DG, LCs 12L & 12G, IVC 44 ft all areas55 ft all areas, 29 ft all open areas, Deaerator Storage Tank Stand, Cold Chem Lab, ando T TGBStartup Feedwater PumpMAB Hot Chem Lab, High Energy Valve Room 80Other IVC 44 ft all areas, RCB all areas, ESF DGB all areasTGB Deaerator Storage Tank Stand, Cold Chem Lab, Startup Feedwater PumpDemineralizer Resin Loading Area 329, Demineralizer Valve Operating Row Area238, Filter Valve Operating Row Area 237SHot Chem Lab, Radwaste Control Room, Valve Mezzanine Room 64, GWPS Valve0 m MAB Room 68J, Water Removal Skid Room 68K, High Energy Valve Room 80, CCWSRooms Common Header Room 106A, CCW HX Room 106E, SRST Entrance Area Room111, SWPS Process Area Corridor Room 218KOther Cubicle 108C, 19 ft Penetration Space, Penetration Areas M-55 and M-76EAB Penetration Space all levels, 4.16 KV Switchgear Rooms all levels, Relay Room 35 ft, RX TripSwitchgear and Rod Control Power Cabinet Room, QDPS Rooms, Aux Shutdown PanelOther IVC 44 ft all areas, RCB all areas, ESF DGB all areasTGB Cold Chem LabS MB o Hot Chem Lab, Radwaste Control Room, Valve Mezzanine Room 64, CCW"' Roomso0 MAB Common Header Room 106A, CCW HX Room 106E2Other Cubicle 335, Penetration Areas M-55 and M-76Roof, Penetration Space all levels, 4.16 KV Switchgear Rooms all levels, Relay Room 35 ft,QDPS Rooms, Aux Shutdown PanelTGB Cold Chem Lab0 Ln MAB Hot Chem LabEAB 4.16 KV Switchgear Rooms all levels, Relay Room 35 ft
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1NOC-AE-1 5003214Page 7 of 18RAI-07The proposed EAL CU1.1 uses the term "reactor vessel flange" to identify the threshold.However, Operating Mode 6 technical specifications may allow Reactor Coolant System (RCS)level below the flange under certain controlled conditions. Please justify further the deviationfrom the endorsed guidance or revise accordingly.STPNOC RESPONSE TO RAI-07STPNOC has revised EAL CU1.1 to accommodate the below-the-vessel-flange conditionsallowed when operating in Mode 6 as follows:(1) UNPLANNED loss of reactor coolant results in RCS level below the procedurallyrequired limit for 15 minutes or longer.STPNOC has revised the CUI.1 Selection Bases as follows:CUI: EAL-1 Selection Basis:RCS inventory is maintained above the reactor vessel flange (39'-3") during refuelingoutages per OPOP03-ZG-0007, Plant Cooldown. RCS level may be lowered belowthe vessel flange for specific purposes (e.g., head removal, mid-loop operations) asdescribed in OPOP03-ZG-0009, Mid-Loop Operation. The 15 minute time frameallows for prompt operator actions to restore RCS level in the event of anUNPLANNED lowering of RCS level below the prescribed operating limit.
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1NOC-AE-1 5003214Page 8 of 18RAI-08The proposed EAL CS1 uses a level that is less than 33% of plenum as the "site-specific level"for EAL declaration. This level is contrary to NRC endorsed guidance which describes the "site-specific level" as 6 inches below the bottom ID of the RCS loop and not the low point of theloop. Additionally, the proposed EAL CS1 does not include the conditions where containmentclosure is established. Please provide a justification for these deviations from NRC endorsedguidance, or revise accordingly.STPNOC RESPONSE TO RAI-08STPNOC maintains that the plenum level being less than 33% in CSl-EAL1 meets the intent ofthe NEI 99-01. The level described in the STP EAL is as close to the specified level of "6 inchesbelow the bottom ID of the RCS loop and not the low point of the loop" without being below thespecified level. STPNOC has revised the CS1-EAL1 bases with an improved description of theReactor Vessel Water Level (RVWL) Monitoring System to support the EAL setpoint. STPNOChas revised the CS1 EALs to include the endorsed CSl-EAL 2 (the condition wherecontainment closure is established) and reinstituted the endorsed CS1-EAL 3. The selectionbases for CSl-EAL1, CSl-EAL 2 and CSI-EAL 3 have been revised to support the EALchanges.(1) a. CONTAINMENT CLOSURE not established.ANDb. RCS level less than 33% of plenum(2) a. CONTAINMENT CLOSURE established.ANDb. RCS level less than 0% of plenum(3) a. RCS level cannot be monitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:* Reactor Containment Building, 68'-0" Area Radiation Monitors RE-8055 or RE-8099reading greater than 9,000 mR/hr.OR* Erratic source range monitor indicationOR* UNPLANNED rise in ANY of the following sump or tank levels in Table C2 ofsufficient magnitude to indicate core uncoveryCSI: EAL-1 Selection Basis:Per NEI 99-01 Rev. 6, the RCS level indication should be six inches (6") below the bottominside diameter of the RCS loop penetration at the reactor vessel. Six inches (6") below thebottom inside diameter of the RCS hot leg nozzle (elevation 31'-0.5") is elevation 30'-6.5" perOPOP03-ZG-0009, Mid-Loop Operation, Addendum 1, RCS/RHR Simplified Elevation Diagram.The nearest RVWL Monitoring System thermocouples are located 6 inches above (Sensor 6)and 4.9 inches below (Sensor7) the prescribed elevation of 30'-6.5". When water level is at thedesired elevation of 30'-6.5", Sensor 6 will be dry and Sensor 7 will be wet. This conditioncorresponds to a reading of 33% of plenum per OPOP02- 11-0002, RVWL Monitoring System,Addendum 1, RVWL Sensor Elevations.
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1NOC-AE-1 5003214Page 9 of 18CSI: EAL-2 Selection Basis:Per NEI 99-01 Rev. 6, the RCS level indication should be approximately the top of active fuel(TAF). The RCS level which corresponds to the top of the active fuel is 28'-2" (OPOP03-ZG-0009, Mid-Loop Operation, Addendum 1, RCS/RHR Simplified Elevation Diagram). The nearestReactor Vessel Water Level Monitoring System thermocouple to TAF is Sensor 8 at elevation29'-2.7". Use of RVWL to approximate TAF; with the inherent gap of 12 inches betweenindicated level and actual level, is acceptable for the purposes of signaling that the threat to thepublic is reduced when CONTAINMENT CLOSURE is established.CSI: EAL-3 Selection Basis:As RCS level drops the dose rates above the core will rise. Area Radiation Monitors RE-8055and RE-8099 are located on the 68'-0" elevation of the reactor containment building. Theirlocations are identified on drawing 9C129A81105. Their range (0.1 mR/hr to 10,000 mR/hr) isidentified in Table 12.3.4-1 of Section 12 of the UFSAR. A rising trend on these monitors can bean indication that core uncovery is occurring. Additionally, erratic source range monitorindications, or large level rises in the tanks listed can give further indication of core uncovery.The threshold value for radiation monitors RE-8055 and RE-8099 was based on CalculationSTPNOC013-CALC-006 Rev.1. The calculated monitor response is 22.4 R/hr when RCS levelis at the top of the active fuel and 6 R/hr at one foot above the top of active fuel. The high rangeof these monitors is 10 R/hr. The value of 9,000 mR/hr was selected to ensure that thethreshold is readily assessable and within the calibrated range of the monitor. The thresholdvalue of 9,000 mR/hr corresponds to a water level approximately 8 inches above the top of theactive fuel with the reactor head on; which provides an additional indication that RCS levels arenear the point of fuel uncovery. These monitor readings in conjunction with the other thresholdvalues allow for an accurate assessment of the EAL.Core uncovery can be determined by the secondary indications listed in this EAL. Thesecondary indicators of inventory loss include a list of tanks/sumps found in OPOP04-RC-0003,Excessive RCS Leakage. Since other system leaks could raise levels in various tanks andsumps, the list has been limited to the tanks and sumps that would have the highest probabilityof indicating RCS leakage inside the Reactor Containment.
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1NOC-AE-15003214Page 10 of 18RAI-09The proposed EAL CG1 does not incorporate EAL CG1.1 from the endorsed guidance, andinsufficient justification was provided for this deviation.a. Please provide further explanation as to why this threshold was not developed, or reviseaccordingly to incorporate.b. The exclusionary note, from the endorsed guidance, is important to maintain as intendedto ensure consistent implementation. Please justify why it was not added, or reviseaccordingly.STPNOC RESPONSE TO RAI-09STPNOC has revised EAL CG1 to incorporate EAL CG1.1 from the endorsed guidance.Additionally, STPNOC has renumbered the current EAL CG1.1 to CGI.2 and has restored theexclusionary note to its endorsed form.(1) a. RCS level less than 0% of plenum for 30 minutes or longer.ANDb. ANY indication from Table C1.(2) a. RCS level cannot be monitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:" Reactor Containment Building, 68'-0" Area Radiation Monitors RE-8055 or RE-8099reading greater than 9,000 mR/hr.OR" Erratic source range monitor indicationOR" UNPLANNED rise in ANY of the following sump or tank levels in Table C2 of sufficientmagnitude to indicate core uncovery.ANDc. ANY indication from Table C1.Table Cl: Containment Challenge* CONTAINMENT CLOSURE not established** >4% hydrogen exists inside containment* UNPLANNED rise in containment pressure* If CONTAINMENT CLOSURE is re-establishedprior to exceeding the 30-minute time limit, thendeclaration of a General Emergency is not required.Table C2: RCS Leakage* Containment Normal Sump* Pressurizer Relief Tank (PRT)" Reactor Coolant Drain Tank (RCDT)* MAB Sumps 1 thru 4* Containment Penetration Area Sump* SIS/CSS Pump Compartment Sump
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1NOC-AE-15003214Page 11 of 18RAI-10The proposed Loss of RCS Barrier due to Category 3, RCS Activity / Containment Radiation,Threshold A, contains a plant-specific basis discussion where temperature induced currents asthe result of an RCS leak would preclude the use of containment radiation monitors (RT-8050and RT-8051) for approximately 40 minutes, and a secondary system break would preclude theuse of the containment radiation monitors for 90 minutes.a. Please add this information to the table as the table is the decision-maker tool used forEAL determination, or justify how this information will consistently be used by EALdecision-makers.b. Please explain why these limitations were not included for Containment Barrier PotentialLoss threshold 3.A.1, or revise accordingly.c. Please explain why these limitations were not included for Fuel Clad Barrier Lossthreshold 3.A.1, or revise accordingly.STPNOC RESPONSE TO RAI-10In the EAL Fission Product Barrier Table (Table 9-F2), STPNOC has revised Loss of RCSBarrier due to Category 3, RCS Activity / Containment Radiation, Threshold A, to contain theplant-specific basis discussion of temperature induced currents (TIC) as a Note; see below. TICis a noticeable impact to the radiation reading for a RCS Barrier Loss because the resultantradiation levels are near the radiation monitor background level.NOTE: Temperature induced current (TIC) as the result of an RCS leakprecludes the use of containment radiation monitors (RT-8050 and RT-8051) for approximately 40 minutes following an RCS leak and 90minutes following a steam line break.Additionally, STPNOC has revised the bases for the Containment Barrier Potential Lossthreshold 3.A.1 and the Fuel Clad Barrier Loss threshold 3.A.1 to state that TIC is not a.limitation for these events.Temperature induced current (TIC) limitations are not applicable to theContainment Barrier Potential Loss threshold 3.A.1 (Fuel Clad BarrierLoss threshold 3.A. 1) because the expected radiation dose for this eventoverwhelms the TIC effect. This is discussed in the 1OCFR50.59evaluation 04-8245-60 associated with DCP 04-8245-33.
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1NOC-AE-15003214Page 12 of 18RAI-11The proposed HU4 EAL does not include the independent spent fuel storage installation (ISFSI)as an area of concern for EAL HU4.3 and HU4.4. Please justify further or revise accordingly.STPNOC RESPONSE TO RAI-11STPNOC has revised HU4.3 and HU4.4 to include the ISFSI as an area of concern.(3) A FIRE within the ISFSI OR plant PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.(4) A FIRE within the ISFSI OR plant PROTECTED AREA that requires firefightingsupport by an offsite fire response agency to extinguish.
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1NOC-AE-15003214Page 13 of 18RAI-12The proposed EAL HA5 appears to cover a wide range of rooms or areas during all modes ofoperation.a. Please verify the plant areas identified for EAL RA3.2 reflect only those areas requiredfor normal plant operations, cooldown, or shutdown, and that access to these areas isrequired, i.e., cannot be operated remotely. Please provide evidence of this verification,or revise as necessary to support accurate and timely assessment. In addition, consideradding operating mode specificity to the listed areas if applicable.b. For EAL HA5, please provide justification for the omission of the control room as a plantarea where access is needed to support normal plant operations, cooldown, orshutdown.STPNOC RESPONSE TO RAI-12STPNOC has revised EAL RA3.2 to include a listing of plant areas that require access fornormal plant operations, cooldown, or shutdown and components in these areas cannot beremotely operated. Additionally, modes of applicability have been included for each area. Seethe Response to RAI-6 for details.STPNOC has revised EAL HA5.la to include the control room as a plant area where access isneeded to support normal plant operations, cooldown, or shutdown.1 a. Release of a toxic, corrosive, asphyxiant or flammable gas into the Control Room orANY of the plant rooms or areas listed in Table H3/R2:ANDb. Entry into the room or area is prohibited or impeded..... .. .. TABLE H3/R2: Plant Areas RequiringAccess.Other Aux Boilers, Lighting DG, LCs 12L & 12G, IVC 44 ft all areasLU0 83ft turbine area, 55ft all areas, 29ft all open areas, Deaerator Storage Tank Stand, Cold0 TGB2E Chem Lab, Feed Booster Pumps and Startup Feedwater PumpMAB Cubicle 335, Hot Chem Lab, CVCS Chemical Mixing Tank Room, Boron Analyzer Room 235AOther Aux Boilers, Lighting DG, LCs 12L & 12G, IVC 44 ft all areaso.I TGB 55 ft all areas, 29 ft all open areas, Deaerator Storage Tank Stand, Cold Chem Lab, and2Startup Feedwater PumpMAB Hot Chem Lab, High Energy Valve Room 80Other IVC 44 ft all areas, RCB all areas, ESF DGB all areasTGB Deaerator Storage Tank Stand, Cold Chem Lab, Startup Feedwater PumpDemineralizer Resin Loading Area 329, Demineralizer Valve Operating Row Area238, Filter Valve Operating Row Area 237,,, Hot Chem Lab, Radwaste Control Room, Valve Mezzanine Room 64, GWPS Valvem MAB Room 68J, Water Removal Skid Room 68K, High Energy Valve Room 80, CCWSRooms Common Header Room 106A, CCW HX Room 106E, SRST Entrance Area Room111, SWPS Process Area Corridor Room 218KOther Cubicle 108C, 19 ft Penetration Space, Penetration Areas M-55 and M-76Penetration Space all levels, 4.16 KV Switchgear Rooms all levels, Relay Room 35 ft, RX TripSwitchgear and Rod Control Power Cabinet Room, QDPS Rooms, Aux Shutdown Panel
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1NOC-AE-15003214Page 14 of 18T.ABL.E Fl3.R.2: Plant Areas Req umiing*Access -C6rttinuedOther IVC 44 ft all areas, RCB all areas, ESF DGB all areasTGB Cold Chem LabLU Hot Chem Lab, Radwaste Control Room, Valve Mezzanine Room 64, CCW0Roomso 0" MAB Common Header Room 106A, CCW HX Room 106EOther Cubicle 335, Penetration Areas M-55 and M-76EAB Roof, Penetration Space all levels, 4.16 KV Switchgear Rooms all levels, Relay Room 35 ft,QDPS Rooms, Aux Shutdown PanelTGB Cold Chem Lab0o0 L MAB Hot Chem LabEAB 4.16 KV Switchgear Rooms all levels, Relay Room 35 ft
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1NOC-AE-15003214Page 15 of 18RAI-13For EALs HS6 and HG1, please consider the addition of operating mode specificity to the listedsafety functions to preclude event classification when these safety functions are no longerneeded in accordance with site technical specifications, or provide rational as to why this wouldnot be appropriate.STPNOC RESPONSE TO RAI-1 3STPNOC has revised HS6.1 and HG1.1 to include operating mode specificity to the listed safetyfunctions to preclude event classification when these safety functions are no longer needed inaccordance with site technical specifications.HS6.1 .bb. Control of ANY of the following key safety functions in Table H2 is notreestablished within 15 minutes in MODES 1, 2 or 3 ONLY.Table H2: Safety Functions* Reactivity control* Core cooling* RCS heat removalHG1.1.bb. ANY of the following safety functions in Table H2 cannot be controlled ormaintained in MODES 1, 2 or 3 ONLY.Table H2: Safety Functions* Reactivity control* Core cooling* RCS heat removalSTPNOC has revised the EAL Selection Bases for HS6: EAL-1 and HG1: EAL-1 to include thefollowing:The mode applicability conditioning statement for Table H2 is based on the TechnicalSpecification Operability requirement for the following functions of the RemoteShutdown System:* Core reactivity control (initial and long term)* RCS pressure control" Decay heat removal via the AFW System and the SG safety valves or SGPORVs" RCS inventory control via charging flow, and* Safety support systems for the above functions.
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1NOC-AE-15003214Page 16 of 18RAI-14For EAL SU4, please explain why consideration should be given for SU4.3. The use of150 gallons per day may be the technical specification limit for primary-secondary leakage, butthis equates to -0.1 gallons per minute when the expectation for the Notification of UnusualEvent classification is 25 gallons per minute for 15 minutes or longer. The NRC endorsedguidance allows for this value in situations where licensees do not have a specific steamgenerator tube leakage value applicable to the initiating condition. Please justify or reviseaccordingly.STPNOC RESPONSE TO RAI-14STPNOC has revised SU4.3 as follows:(3) Leakage from the RCS to a location outside containment greater than 25 gpm for 15minutes or longer.STPNOC has revised EAL-3 Selection Basis as follows:The STP Technical Specification limit for primary-to-secondary leakage is 150 gallons perday through any one steam generator, but the specification does not specify the type ofleakage. Therefore, STPEGS will use the leakage outside containment; which may includeSG Tube Leakage, at 25 gpm for 15 minutes or longer in accordance with NEI 99-01 Rev. 6guidance.
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1NOC-AE-15003214Page 17 of 18RAI-15For EAL SU5 and SA5, please provide justification for removing the basis discussion that wasincluded in NRC approved guidance that actions taken at back panels or other locations withinthe Control Room, or any location outside the Control Room, are not considered to be "at thereactor control panels."STPNOC RESPONSE TO RAI-15STPNOC has revised the Bases discussion for EAL SU5 and SA5 to include the discussionincluded in the NRC approved guidance that actions taken at back panels or other locationswithin the Control Room, or any location outside the Control Room, are not considered to be "atthe reactor control panels."SU5 BasesA manual action at the reactor control panels is any operator action, or set ofactions, which cadses the control rods to be rapidly inserted into the core (e.g.,initiating a manual trip). This action does not include manually driving in controlrods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside theControl Room, are not considered to be "at the reactor control panels".SA5 BasesA manual action at the reactor control panels is any operator action, or set ofactions, which causes the control rods to be rapidly inserted into the core (e.g.,initiating a manual trip). This action does not include manually driving in controlrods or implementation of boron injection strategies. If this action(s) isunsuccessful, operators would immediately pursue additional manual actions atlocations away from the reactor control consoles (e.g., locally opening breakers).Actions taken at back-panels or other locations within the Control Room, or anylocation outside the Control Room, are not considered to be "at the reactorcontrol panels".
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1NOC-AE-15003214Page 18 of 18RAI-16The definition of "Containment Closure" is expected to be the STP site-specific definition, notthe generic terminology from the endorsed guidance. Please justify or revise accordingly.STPNOC RESPONSE TO RAI-16STPNOC has revised the definition of CONTAINMENT CLOSURE to be site specific as below.This definition is derived from OPGP03-ZO-0035, Reduced RCS Inventory Operations.CONTAINMENT CLOSURE: Those actions necessary to place the RCB in theclosed containment condition that provides at least one integral barrier to the releaseof radioactive material. Sufficient separation of the containment atmosphere from theoutside environment is to be provided such that a barrier to the escape of radioactivematerial is reasonably expected to remain in place following a core melt accident.