ML031631045

License Amendment, Eliminate Shutdown Actions Associated with Radiation Monitoring Instrumentation

ML031631045
Person / Time
Site:	South Texas
Issue date:	06/09/2003
From:	Minns J NRC/NRR/DLPM/LPD4
To:	Sheppard J South Texas
Minns J, NRR/DLPM, 415-3166
Shared Package
ML031631055	List: ML031630637 ML031631045
References
TAC MB4053, TAC MB4054
Download: ML031631045 (17)

Text

June 9, 2003 Mr. James J. Sheppard President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS ON PROPOSED CHANGE TO RADIATION MONITORING TECHNICAL SPECIFICATIONS (TAC NOS. MB4053 AND MB4054)

Dear Mr. Sheppard:

The Commission has issued the enclosed Amendment No. 153 to Facility Operating License No. NPF-76 and Amendment No. 141 to Facility Operating License No. NPF-80 for the South Texas Project, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 14, 2002, as supplemented by letters dated July 29, 2002 and March 27, 2003.

The amendments revise TSs to eliminate shutdown actions associated with radiation monitoring instrumentation. The proposed changes will enhance plant reliability by reducing exposure to unnecessary shutdowns, increasing operational flexibility, and relaxing certain other restrictions.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

John Minns, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos.: 50-498 and 50-499

Enclosures:

1. Amendment No. 153 to NPF-76

2. Amendment No. 141 to NPF-80

3. Safety Evaluation cc w/encls: See next page

Mr. James J. Sheppard June 9, 2003 President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483

SUBJECT:

SOUTH TEXAS PROJECT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS ON PROPOSED CHANGE TO RADIATION MONITORING TECHNICAL SPECIFICATIONS (TAC NOS. MB4053 AND MB4054)

Dear Mr. Sheppard:

The Commission has issued the enclosed Amendment No. 153 to Facility Operating License No. NPF-76 and Amendment No. 141 to Facility Operating License No. NPF-80 for the South Texas Project, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 14, 2002, as supplemented by letters dated July 29, 2002 and March 27, 2003.

The amendments revise TSs to eliminate shutdown actions associated with radiation monitoring instrumentation. The proposed changes will enhance plant reliability by reducing exposure to unnecessary shutdowns, increasing operational flexibility, and relaxing certain other restrictions.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice.

Sincerely,

/RA/

John Minns, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos.: 50-498 and 50-499 DISTRIBUTION:

PUBLIC

Enclosures:

1. Amendment No. to NPF-76 PDIV-1 R/F

2. Amendment No. to NPF-80 G. Hill (4)

3. Safety Evaluation RidsNrrDlpmLpdiv (HBerkow)

RidsNrrDlpmLpdiv1 (RGramm) cc w/encls: See next page RidsNrrPMMThadani RidsNrrPMMJLMinns RidsNrrLAMMcAllister RidsNrrDripRorp RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn4MailCenter (AHowell)

S. Athavale Package No.: ML031631055 Chang-Yang Li TS: ML031630637 R. Giardina ACCESSION NO: ML031631045 *see previous concurrences NRR-058 OFFICE PDIV-1/PM PDIV-1/LA PDIV-1/PM DSSA/SPLB DIPM/ DRIP/RORP OGC* PDIV-1/SC DE/EEIB** IEHB NAME JMinns MMcAllister MThadani* SWeerakkody* KGibson* RDennig* CBray* RGramm EMarino*

DATE 5/30/03 5/30/03 6/03/03 10/16/02 2/10/03 02/21/03 02/28/03 6/08/03 07/11/02 OFFICIAL RECORD COPY

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-498 SOUTH TEXAS PROJECT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 153 License No. NPF-76

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by STP Nuclear Operating Company* acting on behalf of itself and for Texas Genco, LP, the City Public Service Board of San Antonio (CPS), Central Power and Light Company (CPL), and the City of Austin, Texas (COA) (the licensees), dated February 14, 2002, as supplemented by letters dated July 29, 2002, and March 27, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

• STP Nuclear Operating Company is authorized to act for Texas Genco, LP, the City Public Service Board of San Antonio, Central Power and Light Company, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2.C.(2) of Facility Operating License No. NPF-76 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 153 , and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The STP Nuclear Operating Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within four months from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: June 9, 2003

STP NUCLEAR OPERATING COMPANY DOCKET NO. 50-499 SOUTH TEXAS PROJECT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 141 License No. NPF-80

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by STP Nuclear Operating Company* acting on behalf of itself and for Texas Genco, LP, the City Public Service Board of San Antonio (CPS), Central Power and Light Company (CPL), and the City of Austin, Texas (COA) (the licensees), dated February 14, 2002, as supplemented by letters dated July 29, 2002, and March 27, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

• STP Nuclear Operating Company is authorized to act for Texas Genco, LP, the City Public Service Board of San Antonio, Central Power and Light Company, and the City of Austin, Texas, and has exclusive responsibility and control over the physical construction, operation, and maintenance of the facility.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2.C.(2) of Facility Operating License No. NPF-80 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 141 , and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The STP Nuclear Operating Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented within four months from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: June 9, 2003

ATTACHMENT TO LICENSE AMENDMENT NOS. 153 AND 141 FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 DOCKET NOS. 50-498 AND 50-499 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT v v 3/4 3-28 3/4 3-28 3/4 3-50 3/4 3-50 3/4 3-51 3/4 3-51 3.4 3-52 3/4 3-52 3/4 3-53 3/4 3-53 3/4 3-71 3/4 3-71 3/4 3-72 3/4 3-72 3/4 4-19 3/4 4-19

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 153 AND 141 TO FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80 STP NUCLEAR OPERATING COMPANY, ET AL.

SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499

1.0 INTRODUCTION

By application dated February 14, 2002, as supplemented by letters dated July 29, 2002, and March 27, 2003, STP Nuclear Operating Company (the licensee) requested changes to the Technical Specifications (TSs) for South Texas Project (STP), Units 1 and 2. The supplements dated July 29, 2002, and March 27, 2003, provided additional information that clarified the application, administrative changes to make the wording consistent with the supplements, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on April 2, 2002 (67 FR 15629).

In its submittal the licensee stated that inoperable radiation monitoring instrumentation has little or no direct effect on plant safety, and generally there are effective compensatory actions that can be taken for inoperable radiation monitoring instrumentation. The proposed changes will enhance plant reliability by reducing its exposure to unnecessary transients due to shutdowns, and will therefore increase operational flexibility, improve the licensees utilization of resources, and reduce the operator burden.

The licensee stated that its risk-insights evaluation ranked the affected radiation monitors as either non-risk-significant or very low safety-significant, and found the likelihood of the initiating events to be very small. The licensee stated that the proposed compensatory actions are based largely on requirements that have already been accepted in other industry applications based on NUREG-1431, "Standard Technical Specifications, Westinghouse Plants."

2.0 REGULATORY EVALUATION

In Section 10 CFR 50.36 of Title 10 of the Code of Federal Regulations (10 CFR), "Technical specifications," the Commission established its regulatory requirements related to the content of the TSs. In doing so, the Commission emphasized those matters related to the prevention of accidents and the mitigation of their consequences. In the Statements of Consideration, Technical Specifications for Facility Licenses: Safety Analysis Reports (33 FR 18610, December 17, 1968), the Commission noted that applicants are expected to incorporate into their TSs those items that are directly related to maintaining the integrity of the physical barriers

designed to contain radioactivity. Pursuant to 10 CFR 50.36, TSs are required to include items in five specific categories related to station operation. Specifically, those categories include:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operations (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plants TS.

The NRC staff subsequently developed the Improved Standard Technical Specifications based upon the criteria in the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," dated July 22, 1993 (58 FR 39132), which was subsequently codified by changes to 10 CFR 50.36 (60 FR 36953, July 19, 1995). The Final Policy Statement describes the safety benefits of the standard technical specifications (STS) and encouraged licensees to use the STS as the basis for both plant-specific TS amendments and complete conversions to the improved STS. In addition, the Final Policy Statement provides guidance for evaluating the required scope of the TSs and defines the criteria to be used in determining which LCOs and associated SRs should remain in the TSs.

3.0 TECHNICAL EVALUATION

The NRC staff has reviewed the licensee's regulatory and technical analyses in support of its proposed license amendments which are described in Attachment 1 of the licensee's submittal.

The detailed evaluation below will support the conclusion that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

The NRC staff had a few concerns relating to the licensees proposed changes described in its initial submittal dated February 14, 2002. The staff discussed these concerns with the licensee during a conference call on April 16, 2002. Following this conference call, the licensee revised a few of the initial proposed TS changes, and re-submitted them in supplemental letters dated July 29, 2002, and March 27, 2003.

The Proposed Change No.1: Would split Action 28 for Functional Unit 10.d, Control Room Intake Air Radioactivity-High, in Table 3.3-3, Engineered Safety Features Actuation System Instrumentation into Actions 28.a, 28.b, 28.c, and 28.d.

The Proposed Change No. 2: would delete: (1) the TS 3/4.3.3, Monitoring Instrumentation, including Limiting Condition for Operation (LCO) 3.3.3.1 and Surveillance Requirements (SRs) 4.3.3.1, Each radiation monitoring instrumentation channel for plant operations shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and DIGITAL CHANNEL OPERATIONAL TEST for the MODES and at the frequencies shown in Table 4.3-3; (2) Table 3.3-6, Radiation Monitoring Instrumentation for Plant Operations, and Action Statements for Action 31, Action 32, Action 33, and Action 34;.

and (3) Table 4.3-3, Radiation Monitoring Instrumentation for Plant Operations Surveillance Requirements.

The Proposed Change No. 3: would revise SR 4.4.6.1.a, which reads, Containment Atmosphere Gaseous and Particulate Monitoring Systems performance of CHANNEL CHECK, CHANNEL CALIBRATION, AND DIGITAL CHANNEL OPERATIONAL TEST at the frequencies specified in Table 4.3-3 to include Reactor Coolant System (RCS) leakage detection instrumentation requirements from Table 4.3-3 The Proposed Change No. 4: would revise Action Statements 39.a and 39.b for Instrument No.

17, Containment - High Range Radiation Monitor, in Table 3.3-10, Accident Monitoring Instrumentation."

The Proposed Change No. 5: would revise the action statement for Action 40 for Instrument No. 16, Steam Line Radiation Monitors, and 22 , Steam Generator Blowdown Radiation Monitor, in Table 3.3-10, Accident Monitoring Instrumentation."

3.1 Evaluation of Proposed Change No. 1:

The proposed Action 28.a, for a condition that the number of operable channels is one less than the required minimum channels operable (i.e., one out of total two channels are inoperable), increases the allowed outage time (AOT) to place the control room makeup and cleanup filtration system (CRM&CFS) in the recirculation and makeup filtration mode (emergency mode) from the current one hour to seven days. The licensees justification is that on a high-radiation signal an operable channel will still function to put the CRM&CFS in the emergency mode unless the failure is due to loss of the output power supply. If the output power supply fails, the operator can manually initiate the function (place the CRM&CFS in the emergency mode). The NRC staff finds this change acceptable because it is consistent with requirements of NUREG-1431, which allows an AOT of seven days based on the low probability of a design-basis accident (DBA) during the proposed AOT and the ability of the remaining operable train and the manual operation to provide the required design capability.

The proposed Action 28.b, for a condition that the number of operable channels is two less than the required minimum channels operable (i.e., two out of total two channels are inoperable),

provides 12-hour AOT as one of the two options. The first option of Action 28.b requires within one hour to initiate and maintain operation of the CRM and CFS (at 100 percent capacity) in the recirculation and makeup filtration mode. Although the proposed one-hour AOT is not consistent with NUREG-1431, it is in line with the current TS Action 28. On the other hand, if the licensee chooses the second option to extend the AOT from one hour to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for inoperability of both radiation detectors, the compensatory requirement to immediately suspend the movement of irradiated fuel assemblies and crane operations with loads over the spent fuel pool in Modes 5 and 6 precludes the potential radiation releases from design basis fuel handling accidents during the extended AOT of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In addition, the licensee indicates that, for a DBA inside containment during Modes 1 through 4, the safety injection (SI) signal will automatically actuate the Control Room's heating, ventilation, and air conditioning (HVAC) to the emergency recirculation mode. The SI actuation is a safety-related, redundant signal.

Furthermore, the emergency procedures require the operator to manually place the Control Room's HVAC in the emergency recirculation mode, if the automatic SI actuation should fail.

The licensee states that the Control Room HVAC radiation monitors at STP are reliable, on an average of less than one inoperable condition per monitor per year according to documented performance history since 1987.

In the supplement change dated July 29, 2002, the licensee further modified Action 28.b to include a provision to permit core alterations, movement of irradiated fuel, and crane operation if the control room recirculation and makeup filtration is operating at 100 percent capacity. The licensee indicated that any two of the three 50-percent trains that comprise the system as currently described in the Bases for Action 28 could meet this configuration. The NRC staff finds that this modification does not change the acceptability of Action 28.b discussed above because the modification is based on the condition of the system at 100 percent capacity.

Based on the compensatory requirement, alternate automatic isolation signals, manual isolation capability, and the performance history of the radiation monitors, the NRC staff finds the proposed Action 28.b acceptable.

The proposed addition of Actions 28.c and 28.d requires immediate suspension of the movement of irradiated fuel assemblies and crane operations with loads over the spent fuel pool in case the required alignment of the CRM&CFS to its emergency mode could not be made within the AOT for the conditions of Actions 28.a and 28.b. The NRC staff finds that the Actions 28.c and 28.d are consistent with requirements of NUREG-1431 and are therefore acceptable.

3.2 Evaluation of Proposed Change No. 2: The proposed change will:

a. Delete the TS 3/4.3.3, Monitoring Instrumentation, including LCO 3.3.3.1 and SRs 4.3.3.1, Each radiation monitoring instrumentation channel for plant operations shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and DIGITAL CHANNEL OPERATIONAL TEST for the MODES and at the frequencies shown in Table 4.3-3.

b. Delete Table 3.3-6, Radiation Monitoring Instrumentation for Plant Operations, and Action Statements for Action 31, Action 32, Action 33, and Action 34.

Delete Table 4.3-3, Radiation Monitoring Instrumentation for Plant Operations Surveillance Requirements.

For Functional Units 1.a, "Containment Atmosphere Radioactivity-High," 1.b.1, RCS Leakage Detection Particulate Radioactivity, and 1.b.2, RCS Leakage Detection Gaseous Radioactivity, Table 3.3-6 defines radiation monitoring instrumentation information required for plant operation, and Table 4.3-3 defines SRs. For the containment atmosphere radioactivity-high function (1.a), with less than the minimum channels operable condition, the current TS Action 31 allows continued operation up to 30 days provided grab samples are analyzed. The current TS Action 31 does not define any required action beyond 30 days. For the RCS leakage detection functions (1.b.1 and 1.b.2), when the required containment atmosphere radioactivity monitors become inoperable, the current Action 34 directs the operation to current TS 3.4.6.1. In case both monitors (gaseous and particulate) are inoperable, current TS 3.4.6.1 requires the licensee to perform the following actions or be in hot-standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold-shutdown in the following 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />s:

a. Restore inoperable monitor within 30 days.

b. Obtain and analyze a grab sample of the containment atmosphere for gaseous and particulate radioactivity at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or

c. Perform a RCS water inventory balance at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The proposed change eliminates the shutdown action for Functional Unit 1.a (containment atmosphere radioactivity-high), and relocates the requirements for Functional Units 1.b.1 and 1.b.2 (RCS leakage detection) to TS 3/4.4.6.1. The containment atmosphere radiation detection function is currently performed by RT-8011 instrumentation, which consists of three detectors: RE-8011A for monitoring particulate, RE-8011B for monitoring iodine, and RE-8011C for monitoring noble gas concentrations in the containment. The particulate detector (RE-8011A) and the noble gas detector (RE-8011C) also perform the RCS leakage detection function. In its submittal the licensee stated that these instruments have no actuation function, and except for the iodine detector (RE-8011B), the instruments governed by this TS are the same instruments also governed by TS 3/4.4.6.1. Except for the iodine monitoring function, the requirements of TS 3/4.3.3 for gaseous and particulate monitors (RE-8011A and RE-8011C) are duplicated by requirements of TS 3/4.4.6.1. Therefore, the licensee is proposing to delete the requirements of TS 3/4.3.3 and Table 3.3-6 that pertain to these instruments and relocate them to TS 3/4.4.6.1.

The proposed change will effectively eliminate the TS requirements for the iodine monitoring function, RE-8011B. The licensee provided the following justifications for this change:

• RE-8011B serves no actuation function (containment ventilation and exhaust isolation is actuated by a separate monitor);

• It has no significant role in accident mitigation;

• It is not used for the determination of Emergency Action Levels;

• The instrumentation is not eliminated; only TS control of this instrumentation is eliminated; and

• The proposed elimination is consistent with the LCO requirements of 10 CFR 50.36(c)(ii).

In its submittal the licensee stated that relocation of the requirements to TS 3/4.4.6.1 is a less restrictive change. The current TS requires both the particulate and the noble gas detector to be operable and imposes an action if either detector is inoperable. With the proposed relocation, an action would be required only if both detectors were inoperable. The description of the particulate and noble gas monitors in the STP updated final safety analyses report (UFSAR) credits these monitors only for RCS leakage detection (UFSAR Sections 5.2.5.2, 11.5.2.3.2). Consequently, it is appropriate for only the TS governing RCS leakage detection to apply. The licensee stated that there is no justification for the current TS 3/4.3.3 actions for this instrumentation since it has no actuation function, and no operator actions are credited in the safety analyses. The licensee further stated that there is adequate redundancy of radiation-monitoring functions on the secondary side of the plant. Elimination of unnecessary plant shutdowns will enhance reliability. Requiring a shutdown for any inoperable radiation-monitoring instrumentation does not contribute to plant safety, and may have a negative effect because a shutdown could cause transient cycles. The proposed requirements are consistent with requirements in NUREG-1431 for monitoring instrumentation for which an alternate means of monitoring is available. Therefore, the proposed change is acceptable to the NRC staff.

3.3 Evaluation of Proposed Change No 3: would revise SR 4.4.6.1.a, which reads, Containment Atmosphere Gaseous and Particulate Monitoring Systems performance of CHANNEL CHECK, CHANNEL CALIBRATION, AND DIGITAL CHANNEL OPERATIONAL TEST at the frequencies specified in Table 4.3-3 and, to read as follows:

a. Containment Atmosphere Gaseous and Particulate Monitoring Systems performance of the following:

1) CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and

2) CHANNEL CALIBRATION at least once per 18 months The licensee states that among the three radiation monitoring instrumentation (RE-8011A, RE-8011B, and RE-8011C), only one (RE-8011B) is actually eliminated. The other two (RE-8011A for particulate and RE-8011C for noble gas) are duplicated by requirements of TS 3/4.4.6, Reactor Coolant System Leakage." The description of the particulate and noble gas monitors in the STP UFSAR credits these monitors only for RCS leakage detection (UFSAR Section 11.5.2.3.2, Table 11.5-1). Consequently, it is appropriate for only the TS governing RCS leakage detection to apply. The NRC staff confirmed the TS requirements of TS 3/4.4.6 for RCS leakage detection, and therefore, the NRC staff finds that consolidating the RCS leakage detection requirements is acceptable.

Current TS 4.3.3.1 requires that each radiation-monitoring instrumentation channel for plant operation shall be demonstrated operable by performance of a channel check, a channel calibration, and a digital channel operational test (DCOT) for the modes and at the frequencies shown in Table 4.3-3. The current frequency for DCOT is at least once per month. The licensee proposes to delete the requirement to perform the monthly DCOT surveillance on radiation detection instrumentation associated with the RCS leakage detection system.

NUREG-1431 specifies a quarterly frequency for this surveillance. In its submittal the licensee stated that the digital radiation monitors are highly reliable and have extensive self-diagnosis capabilities. Also, the plants historical records for these monitors indicate that past monthly DCOT surveillance has not identified any unknown failures which could not be detected by the continuous self-diagnosis tests. Considering the reliability of the instrumentation, the around-the-clock continuous self-diagnosis capabilities, and the historical performance records, the licensee concluded that DCOT frequency can be safely decreased from once a month to once every 18 months. Since the channel calibration requirements encompasses the channel operational test requirements, separate DCOT requirements need not be included in the TSs.

Therefore, only the channel check and channel calibration requirements have been added to the revised TS 4.4.6.1, and separate DCOT requirements are not proposed. The staff agrees with the licensees conclusion that because the digital radiation monitors have extensive self-diagnosis capabilities and continuously self-monitoring its functional capabilities around the clock, also the licensees historical records indicate that these instruments have never failed and are highly reliable, a separate requirement to verify the monitors functional capability is not required and functional-capability requirement can be combined with the channel calibration test requirement. Therefore, changing frequency of DCOT from monthly to once in 18 months along with its calibration is acceptable to the staff.

Based on the above justification, the NRC staff finds the proposed change acceptable.

3.4 Evaluation of Proposed Change No. 4: The proposed Change No. 4 revises Action statements 39.a and 39.b for Instrument No. 17, Containment High Range Radiation Monitor in Table 3.3-10, Accident Monitoring Instrumentation.

The current TS reads as follows:

39.a With the number of OPERABLE channels one less than the Total Number of Channels requirements, restore one inoperable channel to OPERABLE status within 7 days, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

39.b With the number of OPERABLE channels less than the Minimum Channels Operable requirements, restore at least one inoperable channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The proposed change reads as follows:

39.a With the number of OPERABLE channels one less than the Total Number of Channels requirements, restore one inoperable channel to OPERABLE status within 30 days, or submit a Special Report within the next 14 days outlining the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

39.b With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirements, restore at least one inoperable channel to OPERABLE status within 7 days, or submit a Special Report within the next 14 days outlining the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels to OPERABLE status.

The proposed revised statement for Action 39.a extends the current AOT of 7 days to 30 days for a condition where the number of operable channels is one less than the total number of required operable-channels, and the proposed revised statement for Action 39.b extends the current AOT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days for a condition where the number of operable channels is less than the required minimum operable-channels. In addition, the proposed Action 39.a requires the licensee to provide the staff a report within 14 days if the inoperable channel cannot be restored in 30 days, and Action 39.b requires the licensee to report within 14 days if at least one inoperable channel cannot be restored to operable status within 7 days. Changing the AOT for loss of one channel from 7 days to 30 days and for loss of both channels from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days, and removing the requirement to shut down within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> if the AOTs are not met is consistent with NUREG-1431. The proposed change in reporting requirement of 14 days is also consistent with NUREG-1431. Therefore, the NRC staff finds proposed Change No. 4 acceptable.

3.5 Evaluation of Proposed Changes No. 5: The proposed Change No. 5 would revise the action statements for Action 40 for Instrument Nos. 16, Steam Line Radiation Monitor, and 22, Steam Generator Blowdown Radiation Monitor, in Table 3.3-10, Accident Monitoring Instrumentation."

The current TS reads as follows:

40 With the number of OPERABLE channels less than the Minimum Channels Operable requirements, restore at least one inoperable channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The proposed change reads as follows:

40.a With the number of OPERABLE channels less than the Minimum Channels OPERABLE requirements and with a functional diverse channel, restore at least one inoperable channel to OPERABLE status within 30 days, or submit a Special Report within the next 14 days outlining the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the inoperable instrumentation channels to OPERABLE status.

40.b With the number of OPERABLE Channels less than the Minimum Channels OPERABLE requirements and with the diverse channel not functional, restore at least one inoperable channel to OPERABLE status within 7 days, or submit a Special Report within the next 14 days outlining the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the inoperable instrumentation channels to OPERABLE status.

Instrument Nos. 16 and 22 has only one radiation-monitoring channel per line. Therefore, a loss of one channel results in the loss of a function for the affected line. For a condition when the number of operable channels is less than the required minimum channels operable, the current TS Action 40 requires the licensee to restore the inoperable channel to operable state in an AOT of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or requires the plant to be in hot standby within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The proposed change will increase the AOT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days provided a functional diverse-channel is operable, and remove the requirement of being in hot standby within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In addition to the regular monitoring channel, if a diverse channel is designated for each Instrument Nos. 16 and 22, then each of these functions could be considered to have two redundant channels (one regular channel and other the designated diverse functional channel).

In that case, the proposed actions 40.a and 40.b will be consistent with requirements of NUREG-1431, because NUREG-1431 requirements related to these functions are based on two redundant channels per function. The NRC staff believes that, for taking a credit for any functional diverse-channel, it is required that the designated functional diverse channel be equivalent to or better than the regular monitoring channel on the basis of its safety grade, quality, reliability, availability, and SRs. In its submittal the licensee has identified Instrument Nos. 16 and 22 as the acceptable functional diverse channels designated for each other.

These functional units are equivalent to each other; therefore, the proposed change makes it consistent with requirements of NUREG-1431, and therefore, the proposed change is acceptable to the NRC staff. The proposed change in reporting requirement of 14 days is consistent with the requirement of NUREG-1431. Therefore, the NRC staff finds proposed Change No. 5 acceptable.

Based on the above evaluation, the NRC staff agrees with the licensee that the proposed amendments will not increase the probability or consequences of an accident previously evaluated or create the possibility of a new or different kind of accident from any accident previously evaluated. The radiation monitors affected by the proposed change are not credited

for the prevention of any accident not evaluated in the safety analysis. The core damage frequency in the STP probabilistic risk assessment is not impacted by the proposed changes.

Therefore, the NRC staff finds the proposed changes acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Texas State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (67 FR 15629 dated April 2, 2002). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: S.V. Athavale Chang-Yang Li R. Giardina J Minns Date: June 9, 2003

South Texas, Units 1 & 2 cc:

Mr. Cornelius F. OKeefe A. H. Gutterman, Esq.

Senior Resident Inspector Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1111 Pennsylvania Avenue, NW P. O. Box 910 Washington, DC 20004 Bay City, TX 77414 Mr. T. J. Jordan, Vice President A. Ramirez/C. M. Canady Engineering & Technical Services City of Austin STP Nuclear Operating Company Electric Utility Department P. O. Box 289 721 Barton Springs Road Wadsworth, TX 77483 Austin, TX 78704 S. M. Head, Manager, Licensing Mr. L. K. Blaylock Nuclear Quality & Licensing Department Mr. W. C. Gunst STP Nuclear Operating Company City Public Service Board P. O. Box 289, Mail Code: N5014 P. O. Box 1771 Wadsworth, TX 77483 San Antonio, TX 78296 Environmental and Natural Resources Mr. C. A. Johnson/A. C. Bakken Policy Director AEP Texas Central Company P. O. Box 12428 P. O. Box 289 Austin, TX 78711-3189 Mail Code: N5022 Wadsworth, TX 77483 Jon C. Wood Matthews & Branscomb INPO 112 East Pecan, Suite 1100 Records Center San Antonio, TX 78205 700 Galleria Parkway Atlanta, GA 30339-3064 Arthur C. Tate, Director Division of Compliance & Inspection Regional Administrator, Region IV Bureau of Radiation Control U.S. Nuclear Regulatory Commission Texas Department of Health 611 Ryan Plaza Drive, Suite 400 1100 West 49th Street Arlington, TX 76011 Austin, TX 78756 D. G. Tees/R. L. Balcom Brian Almon Texas Genco, LP Public Utility Commission P. O. Box 1700 William B. Travis Building Houston, TX 77251 P. O. Box 13326 1701 North Congress Avenue Judge, Matagorda County Austin, TX 78701-3326 Matagorda County Courthouse 1700 Seventh Street Bay City, TX 77414 May 2003

South Texas, Units 1 & 2 Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P.O. Box 13087 Austin, TX 78711-3087 Mr. Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Division P. O. Box 12157 Austin, TX 78711 Mr. Ted Enos 4200 South Hulen Suite 630 Ft. Worth, Texas 76109